On the 16th March, UK Government made the following announcement on its website:
“New, long-term environmental targets have been announced by the government today. The proposed targets are a cornerstone of the government’s Environment Act which passed into law in November last year.”
These are 13 in number and, the government went on to tell us, “the proposed targets will now be subject to an eight week consultation period where government will seek the views of environment groups, local authorities and stakeholders.”
I have completed the consultation personally, and would urge you to do the same. This explains my thinking on each of the targets, one by one. First, however, an overall assessment of their contribution to the pressing urgency of environmental action in the UK.
These are weak, inadequate proposals. On the one hand, they underestimate the scale of the problem. On the other hand, they suggest the Government has other priorities. If we achieve these targets as stated, the environmental problems in England will become substantially worse than they are already. The Government’s own analysis does not seem to acknowledge how bad this is, let alone the consequences of the problem.
These proposals do not acknowledge the reality of the current baseline. We are in the worst 10% globally for biodiversity loss, among regions that have been desertified in all but name. We are the poorest-performing of the G7 countries, and only Ireland and Malta have fared worse among EU countries. We have set an appalling record in leading the world on environmental degradation.
Yet the proposals are issued as if they will achieve something good by reference to the current situation. They completely fail to recognise that the current situation is what needs to be corrected. They also completely fail to recognise the urgency of it. It needs to be corrected now, not in the coming years.
Specifically, the 13 proposals are as follow, and I give my commentary to each as we go through them:
1. Halt the decline in species abundance by 2030
Right now, species loss in England has reached 50% of pre-Industrial Revolution levels. It has been continuously declining and the decline is accelerating. This target gives us another 8 years during which the decline will continue. How much will this decline amount to, between 2022 and 2030? It will be something between 1% and 10%, but we do not know what. This target is a license to do nothing, while the situation gets worse and worse.
2. Increase species abundance by at least 10% by 2042, compared to 2030 levels.
This proposed target then allows 12 years on from 2030, until 2042, to increase species populations by 10%. Is anyone pretending this addresses the problem? It will barely put right the damage expected in the next 8 years, it will not touch the awful baseline figure that exists now: in excess of 50% loss of English biodiversity.
3. Improve the England-level GB Red List Index for species extinction risk by 2042, compared to 2022 levels.
But 2022 levels are already catastrophic. It is entirely the wrong comparison to make. Achieving this target achieves nothing of any real value. This applies to so many of the proposals, I am sorry you will see a lot of repetition here.
4. Create or restore in excess of 500,000 hectares of a range of wildlife-rich habitats
There are currently in excess of 18 million hectares of land in England in agricultural use. While these are not all monocultural cultivated fields, nor are they wildlife-rich habitats by any standards. 0.5 million hectares will not change the conditions which have been partly to blame for the chronic loss of species and biodiversity in the last century. Once again, achieving this target, let alone as slowly as 2042, will achieve nothing of real value.
5. 70% of the designated features in the Marine Protected Areas network to be in favourable condition by 2042, with the remainder in recovering condition, and additional reporting on changes in individual feature condition.
What we now call Marine Protected Areas have been under assault from industrial scale fishing for decades. They remain a battle-ground in which the levels of environmental degradation are appalling. Bottom trawling and dredging continues to undermine these precious eco-systems which we badly need to maintain the right carbon balance in the atmosphere. Achieving 70% recovery by 2042 of something that is already so badly compromised is a sad admission of defeat.
6. Abandoned metal mines target: Reduce the length of rivers and estuaries polluted by target substances from abandoned mines by 50% by 2037 against a baseline of around 1,500km.
In terms of this and the next target, the comment is the same, and should be seen as a withering criticism. There has been precisely no progress against the objectives of the Water Framework Directive, set by the EU, and subsequently adopted by the UK post-Brexit, since 2010. Setting targets against a 2018 baseline and a 2020 baseline ignores the fundamental ill-health of the baselines. Much more needs to be done, much more quickly.
7. Nutrient targets: to address the two principal sources of nutrient pollution by 2037:
- Reduce nitrogen, phosphorus and sediment pollution from agriculture to the water environment by at least 40% by 2037 against a 2018 baseline.
- Reduce phosphorus loadings from treated wastewater by 80% by 2037 against a 2020 baseline.
See above. These targets are shameful.
8. Water demand: Reduce the use of public water supply in England per head of population by 20% by 2037 against a 2019/20 baseline.
Among 13 different targets, there must be some good ones. Here is one. This target is sensible. It applies to mains water leakage rather than end-use, and is overdue, but nonetheless welcome. (There is no suggestion that householders should be rationed.)
9. Increase tree canopy and woodland cover from 14.5% to 17.5% of total land area in England by 2050.
An improvement of 3 percentage points over a period of 28 years. Will this make any difference to anything? We need to be much more aggressive here – nature based solutions are one of the most effective tools we can use.
10. Reduce residual waste (excluding major mineral wastes) kg per capita by 50% by 2042 from 2019 levels. It is proposed that this will be measured as a reduction from the 2019 level, which is estimated to be approximately 560 kg per capita [24].
Another reasonable suggestion, I think. Landfill waste reduction is one of the few success stories in the UK, having been targeted from as early as the late 90’s by the EU, with the introduction of the Landfill Directive in 1999. Compliance with this policy enforced landfill waste reductions throughout the UK for the last two decades. Continuing this programme of waste reduction is both worthwhile and capable of success.
11. Resource Productivity.
They do not really set a target for this, because the concept is quite vague. It seems to mean resource efficiency rather than productivity, which in turn seems to mean minimising primary materials waste. It is a worthwhile target, but unclear how it will be applied.
12. Air Pollution: Annual Mean Concentration Target (‘concentration target’) – a target of 10 micrograms per cubic metre (µg m-3) to be met across England by 2040.
I have inadequate knowledge to comment on these two final targets and will leave others to do so.
13. Air Pollution: Population Exposure Reduction Target (‘exposure reduction target’) – a 35% reduction in population exposure by 2040 (compared to a base year of 2018).
I am sorry this has been a depressing review of the government’s proposals. But whether you agree with me or not please make your own response to the consultation here. It’s important that everyone’s voice is heard.