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Government must aim higher on environment targets

16 March 2022

Wildlife and Countryside Link welcomes the clear direction the Government is setting to restore nature. But it is challenging Government to aim higher with its new environmental targets, which must be set this year under the Environment Act 2021, or it will fall short of its aim of passing on the natural world in better condition to the next generation.

Welcome moves have been made on a world-leading 2030 target to halt the decline in wildlife, as an apex target for nature’s recovery, and measures to support this. Positive proposals today include:
• Targeting efforts towards our most vulnerable wildlife most at risk of extinction
• A new Nature Recovery Network designation to provide connected nature protection
• Stronger penalties for wildlife crime, including higher fines and tougher sentencing, and
• A statutory basis for “site improvement plans” for our most important wildlife sites.

However, the wider set of targets show major weaknesses. These include:
• A long-term target for wildlife that could see nature in worse condition in 2042 than it is today, and will not meet the Government’s central pledge of passing on nature in better condition.
• No overall target for the state of rivers and streams, and targets for water companies and farmers that ignore major sources of pollution, and are based on inaccurate measures.
• No target for the condition of protected habitats on land, failing to set the target of 75% of Sites of Special Scientific Interest in good condition in law, which is vital for meeting 30x30 goals

At the same time, the Government has released a Nature Recovery Green Paper that does not include the measures needed to ensure nature’s recovery. The Green Paper proposes measures to simplify protection for sites and species, following the UK’s departure from the European Union, but it does not include critical measures to complete the network of protected sites, or to bring existing sites into good condition.

Dr Richard Benwell CEO of Wildlife and Countryside Link said:
“We fully support the Government’s world-leading target to halt the decline of wildlife by 2030, which we campaigned for in the Environment Act. But the Government must raise its sights on today’s proposals or fall far short of the aim of restoring our environment. We can’t afford to take 20 years to stand still on nature’s recovery.

“The Government first promised to pass on nature in better condition in its 2010 manifesto, and again in its 25 Year Environment Plan. Setting a 2042 target that could mean wildlife is less abundant than it is today falls short of that oft-repeated promise.

“The targets for water could give the impression of progress, while allowing the real-world condition of our rivers and streams to decline. The targets miss out major sources of pollution from water and sewage companies, they depend on unreliable methods of measurement, and they set no ambition at all for the overall quality of our rivers. That is completely out of step with demand for healthier rivers.”

Species Abundance Target – long-term biodiversity


England is the first country in the world with a target to halt the decline in the abundance of species by 2030. This target was set on the face of the Environment Act 2021, after a major public campaign by Wildlife and Countryside Link.

Detail proposed today suggests that the Government expects to see species decline to continue until the 2030 target, followed by a slow recovery, with a target for wildlife in 2042 to be increased by just 10% on 2030 levels. That will mean that at best wildlife levels in 2042 will be back at 2022 levels, and could mean that by 2042 there is actually less wildlife in England than there is today.

Campaigners say this 2042 target is clearly not ambitious enough and that Government must put action in place to halt and reverse nature’s decline more quickly.
The Government’s 2018 25 year plan promised to leave the environment in a better state for the next generation. But under the proposed targets today, 25 years on from this promise (in 2042) the state of nature will actually be worse.

It is also concerning that, except for some seabirds, no marine wildlife will be included in species to be targeted and measured under the 2030 goal.

Water and air quality

Water: Under the framework, there is no target for the quality of rivers and streams. Instead, the Government is proposing targets to reduce pollution from particular sectors: agriculture and water.

The absence of an overall target to improve water quality is worrying. Targets to reduce pollution from these particular sectors could be met but overall water quality could remain low, or worsen.

The EU’s Water Framework Directive set a target for overall ecological condition of rivers, but that target expires in 2027, so there will be no long-term ambition in law for improving water quality.

Compliance with targets for water companies and for farmers will be assessed on the basis of modelling data, based on actions taken, rather than real world assessments of pollution in rivers. This leaves considerable scope for error and for the overall condition of rivers and streams to be obscured.

Wildlife and Countryside Link suggests that a new, more ambitious target should be set for the overall condition of rivers, streams and smaller water bodies, aiming for high standards for ecology and human health.

Air: The Government is proposing a welcome target to limit concentrations of fine particulate matter (PM2.5) to 10mcg/m3. However the deadline of 2040 should be brought forward to 2030 given the importance to public and environmental health.

Habitats on land and at sea

The 25 Year Environment Plan included a target for 75% of Sites of Special Scientific Interest (SSSIs) to be in good condition by 2042, but that is a non-statutory, non-binding target.

This target has not been included in the proposals.

Wildlife and Countryside Link points out that only 38% of SSSIs are now in favourable condition and argues that, without a strong and legally binding target for England’s most important nature sites, the chances of halting nature’s decline are reduced.

The Government has argued that it cannot site a target for SSSIs until a review of protected sites is completed, but it has set a target for the condition of marine protected sites, even though those sites are also being reviewed.

The Nature Recovery Green Paper

At the same time, the Government has launched a Nature Recovery Green Paper, proposing changes to the way that sites and species are protected.

It is proposing to merge sites protected under the EU-derived Habitats Regulations, with sites protected under domestic laws. It is also proposing to give the Government the final say in whether or not to designate sites, rather than scientific bodies and nature conservation bodies like Natural England.

Dr Richard Benwell CEO of Wildlife and Countryside Link said: “The Government has asked the right questions about protecting wildlife sites and species in its Green Paper, but it hasn’t come up with the right answer.

“How can we improve protection for wildlife sites and species? The answer isn’t to make changes to names and processes. It is to designate more sites in the network, and increase protection and investment across our important wildlife areas, so that they can no longer be harmed by development, over-exploitation or pollution.”