There is targets fatigue in the air. When goals are set and missed, or goalposts are moved, there’s an understandable cynicism about their value.
But targets can be transformative if they are designed well, prompting regulatory change, better policy and the investment and action needed for delivery. They can even inspire international action, demonstrating political resolve in key negotiations.
The prime minister’s recent promise to protect 30 per cent of land for nature by 2030 highlights the potential opportunity and jeopardy. To be effective, this must avoid confusing the extent of areas such as National Parks with land dedicated to nature, as these do not always coexist happily. Without careful planning this welcome pledge risks becoming just another accounting trick.
Targets across four areas must drive real world improvements
The Environment Bill will lead to legally binding targets in four areas: nature, water, air, and resources and waste. In August, the government published a paper, setting out its intended scope for these targets. The government’s proposals are ambitious, going well beyond the proposed statutory minimum. Nevertheless, important gaps remain, particularly for habitats outside protected areas, the marine environment and freshwater ecosystems.
Nature: Whilst there are welcome proposals for species and the condition of protected areas, resorting to an action target—the extent of uptake of agri-environment schemes—for the wider countryside diminishes the overall ambition for terrestrial biodiversity. Protected areas represent just eight per cent of England’s land area. So, to breathe life into the proposed Nature Recovery Network, we also need a target that measures the extent, condition and connectedness of wildlife-rich habitats outside the protected area network.
At the moment, there is no target proposed for marine species. We recommend a new target for ‘ocean recovery’, to complement the one proposed for highly protected marine areas where damaging activities are prohibited. This would go beyond the Marine Strategy’s current goal of ‘Good Environmental Status’ and its aim to halt declines in marine biodiversity by 2030, to ensure actual recovery by 2037.
Water: For water, the proposal to tackle pressures from abstraction, agriculture and wastewater makes sense, but an outcome target is needed to complete the picture. One that focuses on restoring the natural function of catchments and achieve a higher “clean water” standard would give the necessary focus on freshwater quality and go beyond the current Water Framework Directive target for 2027.
Air: With news this week of the extent that air pollution is seriously affecting most of the world’s population, risking neuro degenerative disorders, the government’s focus on a single pollutant – fine particulate matter (PM2.5) – falls short of the ambition required to protect health and the environment in the long term. While action on PM2.5 particles is needed, many existing air pollution targets expire in 2030, so it is vital to seize the opportunity now to set new limits, exposure reduction targets and emissions targets for all harmful pollutants.
Resources: To complement existing recycling targets, proposals to tackle the whole lifecycle of products by targeting resource efficiency at the outset of production and residual waste at the end are right. All sources of waste should be targeted for minimisation and resource productivity should be broken down by sector and category, with safeguards to ensure that overall resource use does not increase. Adding a target to reduce the UK’s global footprint of environmental harm would address wider impacts and ensure that, in improving the natural environment at home, we are not simply exporting harm abroad.
The Environment Bill framework needs to stand the test of time
The legal framework in the Environment Bill must be strengthened. It is not simply filling a gap in the domestic statute book; it is also expected to replace the target setting function for the environment that has so often been performed at the EU level. In important respects, the proposed framework is weaker than the EU’s legal system for setting targets.
In particular, to establish an effective target setting framework, there should be a clearer link with Environmental Improvement Plans, underpinned by legally binding interim targets and a tightened test of ‘significant improvement’, to ensure that future iterations of the framework remain comprehensive and strong.
Domestic ambition should drive global action
Next year, leaders will gather in China to set global targets for nature under the Convention on Biological Diversity. Early clarity on the ambition for biodiversity targets will help to inspire action across the world.
The 2010 Aichi Targets, which aimed to halt biodiversity loss by 2020, are a testament to our collective failure to protect nature. They were too complex and there were no mechanisms for measurable national action. Time is running out to prevent irreversible loss of nature so strong leadership backed by credible domestic commitments is needed to secure a better result this time round.
The government has taken a bold rhetorical step with its Global Ocean Alliance and Leaders’ Pledge for Nature. Now it needs to add domestic credibility. If these gaps in the scope of targets can be filled and the legal framework shored up, the Environment Bill can become a genuinely world leading example at a crucial moment. But, to really take the lead in advance of global talks, the government should go one step further. The Environment Bill is a timely vehicle for the government to set a ‘State of Nature’ target in line with global ambitions. This is the intention of proposed New Clause 20, which would guarantee, on the face of the bill, that targets will be set to reverse species decline and improve the extent and condition of wildlife rich habitats.
We may not yet know the precise metrics, but the message is clear: unless we stop the decline of nature quickly, the government will fail in its intention to pass the environment on to future generations in better condition. Committing in law to a clear target to restore nature, with binding milestones along the way, would be a genuine sign that we are committed to playing a leading role in this crucial global effort.
The opinions expressed in this blog are the author's and not necessarily those of the wider Link membership.
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