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UK risks major embarrassment on global stage at nature COP15

Government’s long list of unfulfilled green promises leaves nature at risk

The UK risks major embarrassment on the world stage as the most important global meeting on biodiversity in decades – the fifteenth Conference of the Parties (COP15) of the UN Convention on Biological Diversity – starts in Montreal, Canada next week.

COP15 comes at a time when nature is in steep decline across the Earth and the UK is officially one of the most nature-depleted countries in the world. Yet the Government’s decision to press on with The Retained EU Law Bill threatens over a thousand laws that protect the environment, including those that protect wild places and wildlife, and ensure minimum standards for water quality and pollution.

To make matters worse, the Government has “a pattern of missing legislative deadlines” – according to the Office for Environmental Protection – which undermine the UK’s ability to restore nature. Promised but missing policies include:

  1. Environment Act targets: overdue and key to nature’s recovery. With just seven years left to deliver them time is running out to reverse nature declines and clean up rivers
  2. Long promised Environmental Principles to help interpretation of environmental laws and prevent damage to nature: still missing
  3. 30x30 target: to protect 30% of land and sea by 2030, but currently only at 3.22% with no clear plan of how to reach 30% in the next seven years
  4. Landscapes Review: implementation of protections for National Parks & AONBs – overdue
  5. Nature Recovery Green Paper: new protections for sites & species still not published
  6. Highly Protected Marine Areas: designations have yet to be announced
  7. New farm schemes in England to reward farmers for benefits to society: uncertainty as promised elements of the schemes disappear and ambition diminishes
  8. Local Nature Recovery Strategies: new system to plan nature’s recovery but stalled
  9. National Action Plan on Sustainable Use of Pesticides: absent since Spring 2022
  10. River Basin Management Plans: overdue despite appalling state of England’s rivers
  11. Ban on horticultural peat use: yet to introduce legislation to enact the ban
  12. Deposit Return Scheme to cut plastic pollution, especially in the marine environment: promised in 2018 but still not even close to being introduced
  13. Beaver reintroductions: still awaiting plans for allowing this species to roam wild
  14. Bycatch mitigation initiative to protect rare sea life: promised but stalled

All these stalled policies will prevent the UK from attaining the key principle of COP15 talks – to protect 30% of land and sea for nature by 2030. See Editor’s Notes below for more details on this list.

Craig Bennett

Craig Bennett (c) Trai Anfield

Craig Bennett, chief executive of The Wildlife Trusts, says:

“The UK Government has a record of making big environmental announcements to get headlines, but then failing to keep promises. When it does follow-through the policies are so dramatically watered-down that they bear little resemblance to the ambition of the original promise.

“The UK Government is setting a dismal example to the rest of the world. It’s putting nature into reverse gear at a time when it should be setting a world-leading example at COP15. It must take urgent action at home to restore nature otherwise we cannot expect other countries to heed calls for ambitious global policies which help us address the climate crisis.

“If the UK wants to be a world leader on climate and nature it must scrap the appalling Retained EU Law (revocation and reform) Bill which threatens to remove or weaken the laws that protect wild places and species.  It must also reward farmers for restoring the environment, not polluting it, and it must get stuck into its long-overdue to-do list as soon as possible. If not, we’re ill-equipped to deal with the crisis on our own doorsteps let alone advise the rest of the world.”

The interdependency between the nature and climate crises was recognised by the climate COP27 recently – joint solutions were urged. COP15 is a critical summit because there are currently no targets to halt and reverse global declines in habitat and wildlife – and because the previous targets that were set have failed. Nature’s decline matters to us all because it undermines our future ability to grow food, drink clean water, breathe clean air and survive in a warming world. The poor state of natural habitats is intrinsically linked to the climate crisis – restored habitats store carbon and degraded habitats emit carbon – so we cannot solve one without tackling the other.

COP15 runs from 7th – 19th December. See our COP15 briefing. The Wildlife Trusts declared an ambition to help the UK reach the 30 by 30 goal two years ago and have since begun a number of new projects to help nature recover. See our list of 30 by 30 projects here.

Editor’s notes

Defra’s to-do list

The Office for Environmental Protection (OEP), the independent body established to hold government and other public authorities to account on environmental law, wrote to the Environment Secretary recently expressing concern about “a pattern of missing legislative deadlines” by the Government. The OEP warned that the recent failure to set legal targets for nature by the 31st October deadline is not a singular incident of a missed statutory deadline and is a significant failure to comply with landmark domestic legislation. This comes after they highlighted the “slow progress” in implementing the Government’s 25-year environment plan earlier this year.

Despite delay besetting the delivery of a number of the government’s environmental programmes, they face being pushed even further down the priority list as a consequence of the Retained EU Law (Revocation and Reform) Bill. The scale of the review of Retained EU Law (REUL) required by the Bill will cause a huge administrative burden for Defra, which has the largest amount of REUL of any government department. Reviewing over a thousand pieces of law will inevitably displace other priorities and snarl up the delivery of crucial efforts to tackle the nature and climate crisis.

Below is a non-exhaustive collection of things on Defra’s to-do list – they are all major obstacles to nature’s recovery:

  1. Environment Act targets

These targets were promised in the Conservative Party’s 2019 manifesto and have been described by the Government as a “key commitment” of the Environment Act. Even though the Government has been developing these targets for over three years and has had over four months since the public consultation closed, the deadline has been missed and the targets not yet published. Without these targets, the Government also risks missing the legal deadline to publish a new environmental improvement plan, which is required under the Environment Act by the end of January 2023.

  1. Environmental Principles

The Environment Act also requires the Government to publish a new legally binding policy statement to establish environmental principles – such as the precautionary principle – in law. The aim of this is to help guide ministers and policymakers towards opportunities to prevent environmental damage and enhance the environment. Despite being first promised in 2017, and a draft published earlier this year, the final statement is not finalised.

  1. 30x30 target

In 2020, through the ‘Leader’s Pledge for Nature’, the UK Government committed to protecting at least 30% of land and sea for nature by 2030 (its 30x30 target), but little progress has been made. A recent report has found that only 3.22% of England’s land is effectively protected for nature – an increase of just 0.22% compared to 2021.

  1. Landscapes Review

In May 2018 the government asked Julian Glover to lead an independent review into whether the protections for National Parks and AONBs are still fit for purpose. The review’s final report was published on 21 September 2019 with 27 wide-ranging recommendations. The Government responded to the review in January 2022, accepting a number of the review’s recommendations, such as strengthening National Parks and AONB’s statutory purpose to drive nature recovery. Government action to implement these recommendations is long overdue.

  1. Nature Recovery Green Paper

The Government published a consultation in March this year on how protections for sites and species can help best meet their ambition to restore nature and halt the decline in species abundance by 2030. A response to the consultation has yet to be published.

  1. Highly Protected Marine Areas

Last month, the Government announced that they are planning to pilot Highly Protected Marine Areas (HPMAs) following a review led by Lord Benyon last year. HPMAs will give stronger levels of protection to allow nature to fully recover at sea. Ministers have until 6 July 2023 to designate the pilot HPMAs.

  1. New farm schemes (ELMs) to reward farmers for benefits to society: uncertainty as promised elements of the schemes disappear

The UK Governments are in the process of setting out post-EU farming policy frameworks, moving from an area-based subsidy approach towards paying public money for public goods. In England, this comprises the Environmental Land Management (ELM) schemes which will pay farmers for sustainable farming and restore areas for nature. However, progress on these schemes is plagued by delay and uncertainty, with farmers and land managers still unclear on what they will be paid for, putting the success of these schemes in jeopardy.

  1. Local Nature Recovery Strategies: new system to plan for nature’s recovery but stalled

The Environment Bill requires Local Nature Recovery Strategies to be produced by responsible authorities such as county councils. These strategies will cover the whole county and provide a plan for nature’s recovery and reaching the 30 by 30 target. The Government should have published Regulations last spring that set out how the strategies should be developed and what they should contain. They are yet to be published.

  1. National Action Plan on the Sustainable Use of Pesticides

The UK Government consulted on the draft National Action Plan (NAP) in December 2020, but are yet to publish the final version of their plan to replace the 2013 version, despite being promised by Spring 2022. The review of the NAP is a statutory requirement, as well as a commitment under the 25 Year Environment Plan, and intends to lay out a 5-year strategy to increase the sustainability of pesticide use in the UK.

  1. River Basin Management Plans

In June, the Office for Environmental Protection wrote to Defra regarding ongoing delays to the adoption of updated River Basin Management Plans (RBMPs), which are over a year overdue. With all of England’s waters currently failing chemical standards, and only 16% achieving ecological standards, ambitious plans to bring our waters into ‘Good Status’ are urgently required.

  1. Ban on horticultural peat use

The Government have consulted on the ban on the sale of peat and products containing peat earlier this year after the failure of voluntary targets. The response to the consultation was clear, with over 95% of responses calling for a ban on the sale of peat. The Government has since committed to banning the sale of peat and peat containing products in England by 2024 but have yet to introduce legislation to enact this ban.

  1. Deposit Return Scheme

Six years ago, the Government promised the introduction of a deposit return scheme for plastic bottles to cut marine pollution. Defra launched an initial consultation in 2019, saying that it was minded to implement a scheme from 2023. The scheme has yet to be introduced and is now expected late 2024 at the earliest.

  1. Beaver reintroductions

In May 2021, the government announced that it was looking positively towards further reintroductions of beavers in England and changed the legislation to protect wild-living beavers in England and safeguard them from persecution. Following a consultation last year, the government must set out their proposed approach to further reintroductions of beavers in England and the management of the species in the wild.

  1. Bycatch mitigation initiative

Plans to protect rare marine life from being unintentionally caught by fishers were finally approved in August but with no timeframes or measurable actions, and have not come to fruition. The objective to minimise and, where possible, eliminate incidental catches of sensitive marine species is included in the Fisheries Act 2020.

The Environmental Audit Committee published a letter to the Defra SOS raising the committee's concerns that a culture of delay at Defra is holding up progress on a range of promised environmental policies. The main issue raised by the Committee is on Environment Act targets but the letter also expresses concern about delays to the Extended Producer Responsibility scheme for packaging (now delayed until 2024), the Environmental Principles Policy Statement, the Chemicals Strategy and UK REACH, River Basin Management Plans and the National Action Plan for Pesticides. The letter mentions eNGO (including The Wildlife Trusts) joint complaint on targets. The Committee news story is here.

The Convention on Biological Diversity has released the first draft of a new global agreement to managing nature through to 2030. It proposes a key target to: Ensure that at least 30 per cent globally of land areas and of sea areas, especially areas of particular importance for biodiversity and its contributions to people, are conserved through effectively and equitably managed, ecologically representative and well-connected systems of protected areas and other effective area based conservation measures, and integrated into the wider landscapes and seascapes.

The Wildlife Trusts

The Wildlife Trusts are making the world wilder and helping to ensure that nature is part of everyone’s lives. We are a grassroots movement of 46 charities with more than 870,000 members and 38,000 volunteers. No matter where you are in Britain, there is a Wildlife Trust inspiring people and saving, protecting and standing up for the natural world. With the support of our members, we care for and restore special places for nature on land and run marine conservation projects and collect vital data on the state of our seas. Every Wildlife Trust works within its local community to inspire people to create a wilder future – from advising thousands of landowners on how to manage their land to benefit wildlife, to connecting hundreds of thousands of school children with nature every year. 

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