This post is by Dr Graham Tucker, associate of the Institute for European Environmental Policy UK.
Ministers have often said that Brexit would allow the government to improve on the EU’s nature laws and achieve world leading environmental standards. But recently announced reviews of the Habitats Regulations and the Environmental Land Management Scheme in England have brought such promises into question.
A critical test of ambition, in the face of the continuing decline of nature, will be the next generation of targets for biodiversity in the four countries of the UK. In parallel, similar targets and legislation to support them are being agreed in the EU.
What the EU is doing is perhaps the most obvious benchmark. So how do they compare?
If the June 2022 proposals for a new far reaching Regulation on Nature Restoration (Restoration Law) are adopted, IEEP UK’s report, just published, shows that the nature targets proposed so far in Northern Ireland and England would be less ambitious than most of those in the EU.
The targets proposed by DAERA in 2021 for Northern Ireland are widely considered to be weak and poorly defined. Although since updated, they remain unpublished. Of particular current relevance are the nature targets proposed in a Defra consultation in March, as those for species abundance are to be finalised this month, in accordance with the Environment Act.
England’s biodiversity targets diverge from those of the EU
Whilst the headline biodiversity targets are difficult to compare, there is clear divergence between the EU’s more specific proposals and the following four targets, proposed by Defra:
- Halt declines in species abundance by 2030 and increase it by ten per cent by 2042, compared to 2030.
- Improve the England-level GB Red List Index of species extinction risk by 2042, compared to 2022 levels.
- Create at least 500,000 hectares of wildlife-rich habitat outside protected sites by 2042, compared to 2022 levels.
- Seventy per cent of designated features, ie around 150 types of habitat and species, in the Marine Protected Area network to be in favourable condition by 2042.
Of these four targets, halting the decline in species by 2030 will be legally binding under the Environment Act. Ministers claim that this is ‘world leading’. It does indeed have the potential to drive the scale and scope of change needed to halt biodiversity loss, unlike under previous non-binding objectives. However, as is often the case with targets, the devil is in the detail, which reveals serious weaknesses.
England’s ambition is low
First, while halting species declines by 2030 is likely to be challenging, the 2042 ambitions are low. They could mean we only achieve biodiversity comparable with today.
Second, the indicator metric is only based on a representative set of over 1,000 species, with all considered equal. So the target could be met whilst species of high conservation importance decline, if these are balanced by increases in other species, which could include those benefiting from anthropogenic environmental degradation.
Identifying and addressing priorities has always been, and needs to remain, a central element of nature conservation. A more sophisticated target is needed to meet this essential requirement. For example, it could include sub-targets for Priority Species and other declining groups, like farmland birds or seabirds. This is possible, Defra already has indicators for them.
Recognising the need for a complementary target and index for threatened species, Defra has added a target to reduce extinction risk by 2042. But the Red List Index on which it is based is very insensitive and leaves a large gap in coverage for many declining species. It isn’t a substitute for complementary sub-targets.
The wildlife-rich habitat target is being watered down
Another potentially important target is the creation of at least 500,000 hectares of wildlife-rich habitat outside protected sites, which was first included in Defra’s 2018 25 year environment plan. This is expected to complement a target to restore protected areas, which was also included in the 25 year plan, but has yet to be proposed by Defra.
Unfortunately, under current Defra proposals, the wildlife-rich habitat target is being watered down. As explicitly stated in the 25 year plan, habitat restoration should focus on Priority Habitats. But this has been left out of current proposals without any explanation.
Defra has also broadened the definition of what is considered ‘wildlife-rich’, for example, potentially including many forms of restored grassland, new broadleaved woodland and any hedgerow that is next to a bank or ditch. In reality, many of these will not be wildlife-rich. Moreover, Defra’s supporting evidence report for the proposals indicates that the target would probably be mainly achieved through the creation of modest biodiversity value habitats. This will not provide the increase in Priority Habitats and other real wildlife-rich habitat that is desperately needed.
EU targets are more specific, coherent and comprehensive
In contrast to England’s plans, the proposed EU Restoration Law has more comprehensive and coherent aims, with the strongest measures focused on maintaining, restoring and recreating habitats and species of high conservation importance (covered by the Habitats and Birds Directives).
These measures are complemented by more general ecosystem targets, contributing to climate objectives, restoring agricultural habitats, forests and urban areas. Whilst most EU targets for species are less well defined than for England, there are more specific targets for key groups, such as halting the decline in pollinators and increasing farmland bird populations by ten per cent by 2030 where they are most depleted (and five per cent in other areas). No similar target has been proposed for England, despite the existing farmland bird indicator, and English research showing it is feasible with well designed and targeted agri-environment measures.
In short, the proposed biodiversity targets for England are not as ambitious, comprehensive or coherent as most of the EU’s targets. Whilst England’s legal requirement to halt the decline in species abundance is potentially world leading, as it’s currently formulated, the targets could be met whilst major declines in biodiversity continue, including in natural and semi-natural habitats and particularly vulnerable species groups. Similar concerns were raised by NGOs and the Office for Environmental Protection during the consultation.
It remains to be seen whether Defra will respond to these concerns with more meaningful and ambitious targets which prioritise the most depleted truly wildlife-rich habitats. This will be essential if the government is to keep its 2019 manifesto promise of having “the most ambitious environmental programme of any on earth”.