Blog: Why a robust evidence base is essential to a successful Land Use Framework

On 31 January 2025, Defra presented England’s Land Use Framework, kickstarting a 12-week consultation period, seeking views on the vision which is due to be published later this year. Here, Saskia van Dongen, Lead Environment Specialist - Policy Environment at AHDB, explains what it is and the considerations we have raised through our response.

The Land Use Framework presents an approach to inform and improve decision-making on how land is best used and managed to achieve Defra’s land use vision. The vision includes:

• Making space for nature recovery, water and emissions reduction
• Supporting sustainable and resilient food production
• Delivering new infrastructure and housing
• Fixing the foundations for resilient long-term economic growth
• Co-creating plans for delivery

The proposed Land Use Framework is the government’s solution for meeting the increasing land use demands without materially compromising domestic food production.

According to Defra analysis, the negative impact from land use change on food production will be offset by new innovations and productivity improvements which must increase production by 0.5% per year until 2050.

Having compared this rate of increase to total factor productivity's (TFP) historical trends, Defra believes that the impacts of land use change on food production can be broadly offset. 

Defra says the Framework will not be imposed on decision-makers, nor will it prescribe specific land uses in specific places. Instead, it will act as guidance to improve land use decision-making.

What is the Framework proposing?

Defra presented the following indicative figures for potential type and scale of land use change of England’s agricultural land by 2050:

• Change management practices: 81%
• Land sharing: 10% (This was comprised of: substantive land use change, 5%; mix of environment and farming, 4%; and minor changes, 1%)
• Move away from farming: 9%

AHDB’s response to the Framework

The development of the Land Use Framework is a welcomed piece of policy, starting the conversation of how England’s land is best utilised to address competing demands for limited land supply.

The Framework includes “Supporting sustainable and resilient food production” as a key priority. We welcome the recognition of farming within this priority and the need to become more climate resilient.

The Framework recognises that farmers and land managers are already changing management practices to adapt to climate change and more frequent extreme weather events and highlights the role agriculture holds in securing a sustainable future. 

However, we have an underlying concern with some of the evidence base in the proposed framework and therefore what this means to achieve the aims set out, including how the percentage changes in land use have been calculated.

Five key points for consideration

AHDB has raised five key points for consideration which form the base of the answers in our official consultation response.

1. Currently the Framework sets out a vision with high-level aims. It presents indicative figures for potential type and scale of land use change of agricultural land in England. We are concerned this is vague when considering it will need to translate into local action.

Our underlying ask is that the Land Use Framework has clear actionable outcomes based on robust data. Decisions should be made based on current, high-quality, robust data that has been verified and collected at an appropriate scale. That data must be granular enough at a localised level and not use assumptions based on global or national averages. This can be achieved through the completion of comprehensive national environmental baselining.

There also needs to be clarity on how the Framework will be used at the local and regional level, to accomplish the national vision, as for example, changes in the upland or lowland may result in quite different biodiversity or water outcomes.

2. We want to make sure there are clear assumptions being used in the Framework, as we disagree with the basis of the projected increase in yields and productivity and question the use of calories per hectare in land use evaluation. There are several concerns regarding the assumption of increased productivity and how this will be accomplished without detrimentally impacting soil health.

Additionally, with the increase in extreme weather events, food resilience requires a larger margin for error which should be accounted for in assumptions and the development of the outcomes.

The use of calorie per hectare is considered arbitrary and should be broadened out to include macro and micronutrients such as protein, fats, vitamins and minerals which are all key components of a healthy balanced diet. This may have a material impact on the pattern of how land should be used e.g. increase the value of grassland areas that produce livestock products.

3. Accompanying the Framework’s outcomes should be clear prioritisation rules regarding land use change decision making. In the Framework Defra set out three key land use aims:

• Sustainable and resilient food production
• Making space for nature recovery, water and emissions reduction
• Fulfilling housing and transport requirements

These land uses should be treated as priorities, everything should be done to move other land uses into these priority areas. It should be a last resort to take land away from one of these priority areas, even if moving to one of the other priorities.

For example, making best use of brown-field sites for building work, using marginal land by the side of roads and green spaces such as parks and golf courses for environmental commitments. These should all be considered before we strip land away from agriculture.

4. With a finite amount of land, a multifunctional land use approach is crucial. The production of food and restoration of England's nature and wildlife on the same land are not mutually exclusive and policy needs to support this.

Land use decision-making needs to become more strategic and make sure all the environmental implications of land use change are considered before making generalist decisions. For example, we need to consider the below ground biodiversity and soil carbon stocks, not just above ground when it comes to integration of woodland.

It is crucial that all the benefits from the multifunctional use of the land are recognised and reported on, including through the National Inventory. It should also be ensured that planning rules, tenancy agreements and land management plans are appropriate for multi-uses of the land.

5. Land use decision-making needs to incorporate climate resilience and take a long-term view. Decisions need to build in flexibility that acknowledges the multifunctional facet of agricultural land and the changing needs of soil, the land and the ever-growing population.

There needs to be consideration as to how climate change may alter and impact land in five, 10 and 20 years' time and what this means regarding suitability of land use. Land use change in the consultation is proposed with a degree of finality, however, consideration should be given to the reversibility of land use decisions in these increasingly uncertain times.

Climate adaptation needs to be interwoven into decision-making to ensure future suitability and ensure land can meet future environmental, social and economical demands.

Why this matters

The Land Use Framework consultation underpins evidence that will form the basis for wider policy development, including the 25-year Farming Roadmap, The Food Strategy and the review of the Environmental Improvement Plan.

Therefore, it is of the utmost importance that this evidence base is robust and enables the Land Use Framework to meet its full potential.