The government has just published its Environmental Improvement Plan (EIP23) which is the first revision to the 25 Year Environmental Strategy, as required under the Environment Act 2021. This contains a series of “goals” grouped under the following headings:

  • Thriving plants and wildlife
  • Clean air
  • Clean and plentiful water
  • Managing exposure to chemicals and pesticides
  • Maximise our resources, minimise our waste
  • Using resources from nature sustainably
  • Mitigating and adapting to climate change
  • Reduced risk of harm from environmental hazards
  • Enhancing biosecurity
  • Enhancing beauty, heritage and engagement with the natural environment

The Environment Act 2021 establishes a suite of legally binding targets, which will come into force in November this year. The EIP23 sets out the plan to deliver these targets, with policy actions allocated to different government departments, local government, the private sector and Non-Governmental Organisations (NGOs) where appropriate.

The majority of EIP23 covers England-only policy as the environment is primarily a devolved matter. The plan has been developed with support from experts in Defra, Natural England, the Environment Agency, the Forestry Commission, and others. It will help implement national targets for Biodiversity Net Gain (BNG) and Local Nature Recovery Strategies, as contained in the Environment Act, and complements existing policies and initiatives such as the Resources and Waste Strategy, Clean Air Strategy, Government Food Strategy and the Levelling Up White Paper.

In the forward by Prime Minister Rishi Sunak, he claims that the new Environment Improvement Plan is:

”.. a blueprint not just to halt the decline of nature in our country, but to reverse it – changing the trajectory that the country has been on ever since the industrial revolution”.

This generic, but otherwise laudable aim is unlikely to be opposed by many. In addition, references to protecting our “green and pleasant land” and “seizing the opportunities of Brexit” will no doubt appeal strongly to a grassroot base, particularly those living in rural areas. However, there is a plethora of detailed and time-specific actions and commitments in this document – albeit at over 260 pages, it inevitably contains a significant degree of repetition.

The achievement of the EIP23 is heavily reliant on stakeholder participants and “unlocking” private investment in environmental improvement schemes, aided by the Green Finance Strategy which aims to raise £500m in private finance to support nature’s recovery every year by 2027 in England, rising to over £1bn by 2030.

The foremost aim of the EIP23 is “improving nature” to achieve “thriving plants and wildlife”. This is regarded by the government as the “apex goal” of the plan, with the intent of halting the decline in biodiversity by 2030, consistent with the new Global Biodiversity Framework which was agreed at the UN Nature Summit COP15 last year. It emphasises the interlinked threats of climate change and biodiversity loss and says taking action to improve water quality and quantity, and to reduce air pollution, will support improvements in species abundance.

All the other goals are therefore intended to help achieve this apex goal. Specifically, it is proposed to:

  • Implement the Environment Act 2021, including rolling out Local Nature Recovery Strategies to identify areas to create and restore habitat, and Biodiversity Net Gain to enhance the built environment;
  • Launch a Species Survival Fund;
  • Create, restore, and extend around 70 areas for wildlife through projects including new National Nature Reserves, and the next rounds of the Landscape Recovery Projects; and,
  • Protect 30% of our land and sea for nature through the Nature Recovery Network and enhanced protections for our marine protected areas.

Other quantified targets are set out in this section, which reflect those included in the government’s Environmental Targets Consultation last year, include:

  • Halt the decline in species abundance by 2030, and then increase abundance by at least 10% to exceed 2022 levels by 2042;
  • Increase tree canopy and woodland cover from 14.5% to 16.5% of total land area in England by 2050; and
  • 65% to 80% of landowners and farmers will adopt nature friendly farming on at least 10-15% of their land by 2030.

Many respondents to this earlier consultation exercise (including the Wildlife Trust, Friends of the Earth, Greenpeace, Royal Society for the Protection of Birds and the Woodland Trust) consider these environmental targets are inadequate and lack ambition. However, it appears that the government is unwilling to alter these targets at this stage.

With respect to the other goals set out in the EIP23, these are too numerous to cover in this article but those who are interested in specific topics can download the whole document at https://www.gov.uk/government/publications/environmental-improvement-plan

Nevertheless, it is perhaps worth dwelling on three other key goals covered at length in the EIP23 – air quality, water and climate change.

Under Goal 2: Clean Air, the EIP23 stresses that poor air quality “harms the natural environment, affecting our biodiversity, waterways and crop yields” and notes that “in particular, emissions of ammonia have reduced more slowly than the other key pollutants and continue to damage sensitive natural habitats, adding to our existing challenges around house building with nutrient neutrality”.

The government says it has committed to tackling both overall air pollution concentrations and specific hotspots. This includes taking further action on fine particulates (PM2.5), as the pollutant that is most harmful to humans, and on ammonia, which must be reduced to halt species decline by 2030. In respect of the latter, excessive nitrogen accumulation in soils favours a limited selection of common, fast-growing plant species, such as nettles, which outcompete nitrogen sensitive species such as wildflowers. Ultimately this reduces lower overall biodiversity, both in plant species but also animal species which are reliant on specific nitrogen-sensitive plants.

Specific actions to achieve these aims include reducing pollution from domestic burning, the biggest source of emissions of PM2.5, by banning the sale of smoky coal and restricting the sale of wet wood and supporting farmers in reducing ammonia emissions by providing grants for emission-reducing equipment.

However, some of these targets lack precision and others appear, outwardly at least, to be less than ambitious, for example: “By the end of 2040, we will reduce population exposure to PM2.5 by 35% compared to 2018 levels”.

Under Goal 3: Clean and Plentiful Water, the government has committed to tackling nutrient pollution, including by upgrading 160 wastewater treatment works by 2027, encouraging sustainable agriculture, a 50% reduction in water leakages by 2050, restoring 400 miles of river, and establishing 3,000 hectares of new woodlands along England’s rivers.

Quantifiable and pollution-based targets include:

  • Reduce nitrogen, phosphorus and sediment pollution from agriculture into the water environment by at least 40% by 2038, compared to a 2018 baseline, with an interim target of 10% by 31 January 2028;
  • Reduce phosphorus loadings from treated wastewater by 80% by 2038 against a 2020 baseline, with an interim target of 50% by 31 January 2028;
  • Reduce the use of public water supply in England per head of population by 20%, by 31 March 2038;
  • Restore 75% of our water bodies to good ecological status; and
  • Water companies to cut water leakage by 20% by 31 March 2027, 30% by March 2032 and 50% by 2050.

Under Goal 7: Mitigating and Adapting to Climate Change, the government first points out that “restoring the natural world is vital in achieving net zero” and that “we can only reach net zero with Nature-based Solutions”. It also stresses that “we must go further to build the climate resilience of our ecosystems”.

As the government published the Net Zero Strategy in 2021, which sets out its policies and proposals for decarbonising all sectors of the UK economy, the EIP23 offers little more detail on this beyond restating existing commitments. Instead, it focuses on climate change resilience, identifying land use considerations for net zero alongside nature, biodiversity and climate adaptation goals.

Notable actions and initiatives under this section of the plan include:

  • The government will publish a Land Use Framework in 2023, setting out how it will balance multiple demands on our land including climate mitigation and adaptation;
  • Publish the third National Adaptation Programme (NAP3) in 2023 that will set the next  five-year strategy to build the UK’s climate resilience. The current NAP includes delivering over £3 billion in climate financing over the next five years, including £200 million for a new Climate Innovation Facility to scale-up technologies to help deal with the impacts of climate change, such as drought-resistant agriculture and sustainable forestry, in markets where private investors have been reluctant to take on the risk alone;
  • Continue to support the use of Nature-based Solutions, through our International Climate Finance and other Official Development Assistance;
  • Provide incentives and grants to farmers to decarbonise agricultural emissions through adopting sustainable land management approaches, new technology, and innovative practices to improve farm efficiency; and
  • Plant trees and restore peat to create habitats that act as carbon sinks. It is noted that only 13% of England’s peatlands are in a near natural state, and that drained and degraded peatlands are a significant ongoing source of carbon emissions. The existing England Peat Action Plan aims to restore approximately 280,000 hectares of peatland in England by 2050.

Concluding Remarks

Unsurprisingly, the language of EIP23 is peppered with political messages which align with the government’s agenda and which it hopes will appeal to its electorate. It makes bold claims for its achievements (e.g., “we have created or restored wildlife habitats the size of Dorset”) without acknowledging that others, such as environmental NGOs and local authorities, will have played an equal if not more important role in such achievements. The document makes frequent boasts about the UK being “world leading” across a range of environmental matters, often without substantiation. In fact, metrics such as the Earth.Org Global Sustainability Index paint a very different picture, with the UK being well down the rankings for KPIs such as habitat loss, biodiversity and waste management.

However, the EIP23 is clearly a big step forward from the 25 Year Environment Strategy published five years ago and, whilst critics will maintain that it “lacks ambition”, it certainly has some challenging targets embedded within it.

 If the short to longer term goals set out by the EIP23 were to come to fruition, there is a realistic prospect of halting the decline of nature by 2030 and improving it thereafter. This will be monitored by annual performance reports using an Outcome Indicator Framework, comprising a suite of 66 indicators designed to collectively describe environmental change linked to the ten goals of the EIP23. Moreover, under the Environment Act there is a requirement to review and refresh the plan every five years. These in-built monitoring, evaluation and reporting requirements should act to hold the Government to account for its performance against the plan, whichever party is in power at the time.

It is understood that environmental improvement will also be fully reflected in the review of the National Planning Policy Framework (NPPF) later this year. The new system of Environmental Outcomes Reports (EORs) under the Environment Bill will be aligned to EIP23 and ensure that decision makers know how to measure whether or not a particular plan or project contributes to the national Environmental Targets.

On balance, the new Environmental Improvement Plan, in combination with existing and forthcoming laws and policies to protect and enhance the environment, should be applauded. For the first time, there will be a tangible overarching mechanism to enact real change across a wide range of environmental factors and to hard-wire these improvements into the national and local plan-making process.

By Pell Frischmann’s Environment Sector Director, David Thomson.