Preparing for the Land Use Framework: our response to the consultation

As a precursor to the publication of the Land Use Framework in the summer, Defra published its land use consultation a few months ago.

The CLA has submitted a response to the consultation, based on established policy positions and the views of our members. Member opinions were gathered through discussions at 35 branch committees in England, four national committees and two online workshops, as well as discussions with individuals, professional members and other stakeholders. The CLA has also contributed to Defra ministerial roundtables on farm tenancies and food production, and Defra policy discussions on 30by30 and Agricultural Land Classification. The CLA promoted the Defra regional in-person workshops to members and attended four of them.

The CLA has shaped the development of the land use consultation. It has done this by having regular engagement with the Defra land use team, providing evidence to the House of Lords enquiry and submitting a policy briefing on a Land Use Framework to Defra in April 2023 – setting out 11 recommendations, following discussion at CLA committees.

The driver for the Land Use Framework is the need for better spatial planning and decision making on land use, to help manage all the demands on land – agriculture, housing, energy, infrastructure, nature recovery and climate action – to unlock growth, deliver on environmental commitments and ensure food security. It is not intended to be prescriptive or replace the planning system.

The consultation document states that the Land Use Framework will include:

• A set of principles that the government will apply to policy with land use implications
• A description of how policy levers will develop and adapt to support land use change
• A release of land use data and analysis to support public and private sector innovation and spatial decision making and the development of tools to support land managers in practice

The consultation sets out a vision for land use in England, focusing on the need for up to 20% of agricultural land to change to nature, rather than the relatively smaller amounts of land required for housing and infrastructure. They introduced four categories of land use change for nature ranging from integrating land for nature with farming (multifunctional) through to land predominantly for nature.

The consultation is wide ranging and strategic, and has links to many other plans and policies in Defra and wider government that are varying stages of development (Figure 1). On of the challenges of the consultation is understanding the hierarchy and how they will interact and sequence. The aim at a minimum must be for coherence.

The consultation has 24 questions covering the scale of change, principles, drivers and incentive, decision-making, data and skills. The CLA has responded to all the questions, mainly based on established policy positions and informed by the engagement with members during the consultation period.

The main discussion points from the national and branch committees related to a number of subjects. This includes the land use change from agriculture to environmental management and the risks to long-term food security; the protection of the best agricultural land; the quality of the data and understanding of the assumptions in the models and how they might change with new evidence; and, the concerns about how a Land Use Framework will be implemented at national, regional and local level, which is largely unknown.

The key points across the consultation are set out below along with reference paragraph numbers in the response for the detail:

• The CLA supports a strategic Land Use Framework that tests the feasibility and long-term effects of government plans and policies. There must be ongoing monitoring and reporting, of land use change and flexible policy responses to adapt to new circumstances.
• National datasets are rarely accurate at field level, so a process is needed that takes account of landowners’ and land managers’ expertise and knowledge. Defra must address concerns about data ownership, sharing, misuse and privacy and develop safeguards.
• There must be assurances that the deployment at national, regional and local level will not become prescriptive of bureaucratic, or result in zoning that could stifle economic and environmental development and innovation, instead of opening opportunities. The CLA has suggested an additional principle to reflect the intent of supporting decision-making, not imposing.
• Protecting agricultural land for future food security is important but it requires a flexible approach that considers changing climate, farming systems and societal needs, rather than simple designation.
• Land use for farming, woodland and environment should not be part of the planning system, as there are already sufficient controls.
• There needs to be long-term stability in government policies and schemes to support land use change if landowners and managers are to have the confidence to deliver at the scale needed, and delivery on the governments environmental commitments. This should include innovative approaches to building skills that make best use of the mapping information for on-farm and local planning.
• While the CLA welcomes the land use consultation and forthcoming Framework, it is unlikely to solve all the problems. Many decisions on land use come down to a judgement that balances a range of factors, whether formally through the planning system or within individual businesses. It is essential that landowners and managers have the autonomy to make the right decision on land use for their business.