BRIGHT BLUE – WRITTEN EVIDENCE

Submission of written evidence on Biodiversity and Ecosystems

Executive summary

The state of biodiversity

●        We recommend that statutory duties be placed on organisations with an annual turnover of £36 million or more within the UK to monitor and prevent financial flows that could reasonably be related to the International Wildlife Trade (IWT).

●        We recommend a government-backed study on the cost of flytipping enforcement and clean up compared to the cost of running free waste disposal sites where building/domestic waste can be disposed of responsibly. If economically viable, the government should remove the ability of local authorities to charge for the disposal of building/domestic waste at waste disposal sites.

●        We recommend that the UK Government phases out all subsidies for the production of biomass

Evaluating measures to conserve and enhance biodiversity

●        We recommend that the findings of the UK Centre for Ecology and Hydrology’s UK Pollinator Monitoring Scheme is reflected in the UK’s new Environmental Land Management Scheme so that there is a gradual increase in rural payments to farmers, land managers and land owners for ecosystem services that are deemed to be specifically pollinator-friendly.

●        We recommend that every city in the UK, where appropriate, include an urban nature corridor as part of the UK’s new national NRN.

●        We recommend that the UK upholds the EU-ban on neonicotinoids after the Brexit transition period

Co-ordination of UK environmental policy

●        We recommend creating a new Special Envoy for Climate Change and Biodiversity, appointed by the Prime Minister. This role should be filled, and continued beyond 2020, by the President of COP26. The Special Envoy should seek to develop a strong partnership with China ahead of COP15 on the Convention on Biological Diversity (CBD) in October 2020 and COP26 UN Climate Change Conference in November 2020, to build arguments and alliances around tackling both biodiversity decline and climate change.

●        We recommend the establishment of a new ‘Global Nature Conservation Fund’ of at least £1 billion per year from the existing, and future growth in, the UK ODA budget. This fund should be hosted by the Department for Environment, Food and Rural Affairs (Defra) and announced at COP26. Also, the Government should set a target for the UK to be the biggest funder of global conservation efforts through ODA, in proportional terms, by a set date.

●        We recommend making biodiversity a key filter for the allocation and prioritisation of UK ODA funding via DFID.

●        We recommend the adoption of a ‘do no harm’ policy in relation to global nature, such that any aid project that damages or destroys nature should not receive UK ODA. This ‘do no harm’ principle should be an assessment the government makes before signing off any new ODA funding – a ‘Nature Impact Assessment’ The Independent Commission for Aid Impact should determine in all of its evaluations whether any harm to global nature has been caused by any UK ODA supported projects.

●        We recommend the Government commit funding for the Blue Belt Programme at current levels each year beyond 2020 until the full goal of protecting four million square kilometres of UKOT ocean is met.

Economics and biodiversity

●        We recommend the Government trial the ‘kW Days at Sea’ model as a fisheries management measure in future trials, alongside the ‘Days at Sea’ trials for low impact, inshore fisheries.

●        We recommend that the UK’s plastic packaging tax threshold for recycled content should be set at 35% from 30% as soon as feasible, and this threshold should increase if viable on an annual basis thereafter.

●        We recommend establishing a task force to promote and introduce standards on financial disclosures on natural capital for financial actors, similar to the TCFD.

Pairing nature-based solutions to climate change with biodiversity

●        We recommend regularly reviewing and, if necessary, updating, the UK’s afforestation target so it is line with trends in population growth and decarbonisation. This review should be led by the CCC and the Forestry Commission, in consultation with other relevant organisations, on a five-yearly basis.

●        We recommend that every state secondary school in the country should plant and name an area of trees to support the government’s new afforestation target. The school should be granted funding from government to take a selection of pupils on a trip to learn about and do the tree-planting. The location of the tree planting should be decided in conjunction with Forestry Commission, who are responsible for tree-planting targets.

In February 2020, Bright Blue published a report, Global green giant? A policy story, which highlighted declining biodiversity both here in the UK, and abroad. The report looked at climate change, overfishing, changes in land and sea use, and invasive alien species as all contributors to declining biodiversity. After many months of exploration, of consultation, and of thinking, it proposes a comprehensive set of recommendations for to be used by the Government to bolster its agenda in making the UK a conservation nation.

The state of biodiversity

Monitoring the impact of UK activities on biodiversity:

1.1 In 2018, Department for International Development (DfID) and the Foreign Office jointly launched The Wildlife Financial Taskforce with the Duke of Cambridge. This Taskforce seeks to find ways to better tackle criminal gangs facilitating IWT. Organisations on the Taskforce have committed to not facilitate or tolerate financial flows stemming from the IWT.[1] The Taskforce works alongside authorities in countries such as Kenya, Tanzania, Uganda, Botswana and Côte d’Ivoire to launch investigations, seize assets and train law enforcement in East and Southern African countries in order to tackle financial crimes associated with IWT.[2] However, the Wildlife Financial Taskforce, at present, consists of financial organisations that have volunteered. In contrast, there is a compulsory statutory duty for some organisations to prevent slavery in their supply chains, created through the Modern Slavery Act.[3] This obligation applies to commercial organisations which have a turnover of £36 million or more.[4] A similar framework could be used for mandatory monitoring of financial flows that may stem from the IWT. We recommend that statutory duties be placed on organisations with an annual turnover of £36 million or more within the UK to monitor and prevent financial flows that could reasonably be related to the IWT.

1.2 Fly tipping is the deliberate disposal or dumping of larger quantities of litter in a particular area where it is not permitted, such as non-licenced premises or private property. At its very worst, if convicted in a Crown Court by local authorities or the Environment Agency, those prosecuted for major fly tipping can face an unlimited fine or up to five years imprisonment.[5] Fly tipping has been on the rise since 2012, with the vast majority of cases occurring on highways.[6] Between 2017 and 2018, large scale cases of fly tipping cost local authorities £12.2 million in clearance fees.[7] Current fines are clearly failing to deter individuals from fly-tipping. The increase in fly-tipping may also be linked to charging at waste disposal sites. For example, Buckinghamshire County Council charges £20 to dispose of a boiler and £10 to get rid of items such as windows and doors.[8] However, prices do vary across different waste disposal sites. We recommend a government-backed study on the cost of flytipping enforcement and clean up compared to the cost of running free waste disposal sites where building/domestic waste can be disposed of responsibly. If economically viable, the government should remove the ability of local authorities to charge for the disposal of building/domestic waste at waste disposal sites.

Further progress needed on Aichi Targets:

1.3 Despite the Government’s commitment under the CBD (Convention on Biological Diversity), an international legally-binding treaty on the conservation and sustainable use of biodiversity, which requires the elimination of subsidies that are harmful to global biodiversity, the UK continues to subsidise biomass without considering the potential for perverse environmental outcomes. Target 3 of the Aichi Biodiversity Targets states: “By 2020, at the latest, incentives, including subsidies, harmful to biodiversity are eliminated, phased out or reformed in order to minimize or avoid negative impacts, and positive incentives for the conservation and sustainable use of biodiversity are developed and applied, consistent and in harmony with the Convention and other relevant international obligations, taking into account national socio economic conditions.”[9] Consistent with Target 3, the UK Government’s recent 25 Year Environment Plan states that the UK will establish “appropriate mechanisms to screen policies and strategies for potential negative environmental effects overseas.”[10] However, the UK provides subsidies for wood pellets sourced in the US. The evidence available does suggest that this is both harmful to the climate and has a negative ecological effect on areas where it is sourced.[11] We recommend that the UK Government phases out all subsidies for the production of biomass.

Evaluating measures to conserve and enhance biodiversity

How the Environmental Land Management scheme can improve biodiversity:

2.1 Any insect that visits flowers can be considered a pollinator.[12] Pollinators facilitate the reproduction of plants. When pollinators eat pollen or nectar from a plant, pollen often sticks to their bodies, which in effect causes pollinators to spread the pollen when they travel to other plants. The number of pollinators in the UK has been declining dramatically in recent decades.[13] Comparing indicators from 2016 with 1980 highlights a 31% decline in pollinators.[14] Declining pollinator populations is concerning, not least because they are essential to biodiversity and high quality food yield.[15] There are a number of possible causes of declining pollinator populations. However, there is a deficit of conclusive evidence about the extent of each cause, and whether any interactions exist between these causes.[16] Further research is needed for a greater understanding of the troubling decline in pollinators.[17] The UK Centre for Ecology and Hydrology is currently undertaking a major study which monitors the abundance of pollinators and how their populations are changing across Britain.[18] The findings of this study could be reflected in the Environmental Land Management Scheme (ELMS) – the post-CAP rural payments system which the UK Government is introducing which will better reward farmers, land managers and land owners for environmental services and benefits. For example, farmers could be rewarded for pollinator-friendly practices such as reducing chemical use or increasing agroforestry and the planting of wildflowers. We recommend that the findings of the UK Centre for Ecology and Hydrology’s UK Pollinator Monitoring Scheme is reflected in the UK’s new Environmental Land Management Scheme so that there is a gradual increase in rural payments to farmers, land managers and land owners for ecosystem services that are deemed to be specifically pollinator-friendly.

How Nature Recovery Networks should be delivered:

2.2 The Government has outlined its intention for the reintroduction of lost species as part of its 25 Year Environment Plan. It has previously pledged to develop ‘Nature Recovery Networks’ (NRNs) for wildlife restoration.[19] Specifically, 500,000 hectares of wildlife habitats were due to be set aside for a NRN.[20] NRNs identify where habitats and ecosystems are located, then links them via ‘eco-corridors’.[21] The aim is that all ecosystems will be linked together through a NRN. For example, waterways could be fenced off from livestock to allow fauna to re-establish itself along the riverbank. These waterways would then form eco corridors as part of the NRN. Motorway wildlife crossings are another example of how an NRN can operate; they remove motorways as a barrier for wildlife between ecosystems. NRNs also facilitate climate adaptation by allowing wildlife to relocate from their habitats, which are changing due to climate change. Furthermore, they facilitate carbon capture through fauna restoration and afforestation, improve water quality by keeping livestock out of waterways, increase biodiversity through rewilding, and they can reduce the impact of flooding.[22] However, the Government’s plan for an NRN says little about the role that NRNs could play in improving biodiversity in urban areas. The Government has only detailed plans to build an NRN rurally, stating it could be made to “extend into towns and cities” without providing any concrete goals.[23] In light of dwindling pollinator populations, urban areas offer opportunities for suitable, connected habitats to boost pollinator numbers. This is being done in Oslo, Norway, where a ‘bee highway’ has been built through the centre of the city. By extending NRNs into urban areas, it also allows them to be more accessible to people and improve air quality. We recommend that every city in the UK, where appropriate, include an urban nature corridor as part of the UK’s new national NRN.

Other policies for the enhancement of existing natural habitats:

2.3 Neonicotinoids are used as a form of pest control in agriculture. They resemble nicotine in structure. Their use as a pesticide has a proven harmful effect on pollinating species such as bees, reducing pollination rates.[24] In the interest of addressing dwindling pollinator populations, the EU banned their use in 2018, which the UK supported.[25] We recommend that the UK upholds the EU-ban on neonicotinoids after the Brexit transition period.

Coordination of UK environmental policy

COP15 preparations:

3.1 A Special Envoy is a diplomatic position, appointed by the Prime Minister, to engage with relevant representatives from other nations. It is not necessarily a ministerial position, but remains a high profile role and is important to the UK’s international efforts on certain issues. Typically, an envoy is an expert in the field and helps to ensure the UK's continuing role in international discussions. At present, Special Envoys exist for issues ranging from media freedom to gender equality. Examples of recent UK Special Envoys include gender equality, fintech, Yemen, Oman and for Preventing Sexual Violence in Conflict.[26] Recently, the UN appointed the Former Governor of the Bank of England as the UN Special Envoy for Climate Action and Finance. For the UK specifically, the Government has a ‘special representative’ for Climate Change, but this is inside the UN. There is also the role of President of COP26, which is an important and high-profile role, that the UK Government has been keen to secure a suitably high-profile person for.[27] We recommend creating a new Special Envoy for Climate Change and Biodiversity, appointed by the Prime Minister. This role should be filled, and continued beyond 2020, by the President of COP26. The Special Envoy should seek to develop a strong partnership with China ahead of COP15 on the Convention on Biological Diversity (CBD) in October 2020 and COP26 UN Climate Change Conference in November 2020, to build arguments and alliances around tackling both biodiversity decline and climate change.

Addressing biodiversity loss in Overseas Territories and international development:

3.2 ODA is a term that refers to the total amount spent by the UK abroad as aid. The UK has a legal target of spending 0.7% of Gross National Income (GNI) on ODA.[28] The vast majority of the ODA budget is spent through the Department for International Development (DFID), at 72% in 2017.[29] Historically, there has been a pitiful amount of UK ODA spent on global nature conservation. Government funding for global biodiversity conservation, including both bilateral (country-specific) and multilateral sources, averaged £75 million per annum between 2010 and 2013 – the last period for which formal government figures are available. This figure represents only 0.5% of the approximately £14 billion annual UK ODA budget.[30] Contrast this with Germany and the USA, which each provide on average around $600-700 million per annum for global nature conservation.[31] The UK Government’s recent one-off £1.3 billion ODA package for climate change and biodiversity included: £220 million for a new ‘International Biodiversity Fund’, to preserve the world’s endangered species and habitats; and, a £100 million ‘Biodiverse Landscapes Fund’ to invest in the protection of mangroves and forests.[32] This is a good start, with more funding promised for biodiversity-focused development aid. But it is not enough to stem the loss of global biodiversity. This funding needs to be increased to at least £1 billion per year to finance a range of ambitious projects. More broadly, to be a global leader on conservation, the UK should seek to be the country that proportionally spends the most on conservation ODA. We recommend the establishment of a new ‘Global Nature Conservation Fund’ of at least £1 billion per year from the existing, and future growth in, the UK ODA budget. This fund should be hosted by the Department for Environment, Food and Rural Affairs (Defra) and announced at COP26. Also, the Government should set a target for the UK to be the biggest funder of global conservation efforts through ODA, in proportional terms, by a set date.

3.3 DFID, the principle donor of UK Overseas Development Assistance (ODA), has been almost exclusively focused on poverty eradication at the expense of other Sustainable Development Goals (SDGs).[33] As part of the International Development Act 2002, DFID’s focus of ODA has been ‘poverty reduction’ and ‘sustainable development’.[34] However, ODA from DFID has overwhelmingly been concerned with the former focus and not the latter; only a small number of DFID staff focus on international biodiversity, marine or forestry conservation issues.[35] The SDGs includes goals on responsible consumption (SDG12 Responsible Consumption and Production), climate change (SDG13 Climate Action), marine biodiversity (SDG14 Life below Water), and terrestrial biodiversity (SDG15 Life on Land).[36] The poorest developing countries with habitats and biodiversity of global or regional significance should be actively prioritised when receiving Official Development Assistance. This would not undermine poverty alleviation, as nature supports sustainable development and sustainable livelihood creation and poverty alleviation supports nature. The International Development Act 2015 established the international aid expenditure target of 0.7% as a percentage of GNI on international aid, as well as requiring the International Development Secretary to provide a detailed report on international aid spending and its value for money.[37] The International Development Act 2002 outlines that the Secretary of State for International Development may provide “development assistance” or “humanitarian assistance”.[38] Development assistance may be provided by the Secretary of State for International Development if “satisfied that the provision of the assistance is likely to contribute to a reduction in poverty”.[39] We recommend making biodiversity a key filter for the allocation and prioritisation of UK ODA funding via DFID.

3.4 There would be little point increasing ODA allocations to global nature conservation on the one hand, while promoting short-term development that harms global nature on the other. The principle of ‘Do no harm’ is used in humanitarian aid to prevent the impact of an organisation’s actions having a negative impact on affected populations.[40] By adopting a ‘do no harm’ principle in relation to global nature and sustainable development, the UK can ensure that its ODA assists in poverty alleviation whilst not having a negative impact on global nature conservation. Government departments themselves are responsible for ODA expenditure, which must reflect the UK’s Aid Strategy and be consistent with “sustainable development” and “poverty reduction”, as outlined in the International Development Act 2002.[41] The Independent Commission for Aid Impact (ICAI) is a commission independent of government which scrutinises all government department ODA and reports to Parliament via the International Development Committee.[42] ICAI operates in a transparent manner, holding the government to account for aid effectiveness and providing feedback to enhance the effectiveness of future ODA.[43] We recommend the adoption of a ‘do no harm’ policy in relation to global nature, such that any aid project that damages or destroys nature should not receive UK ODA. This ‘do no harm’ principle should be an assessment the government makes before signing off any new ODA funding – a ‘Nature Impact Assessment’ The Independent Commission for Aid Impact should determine in all of its evaluations whether any harm to global nature has been caused by any UK ODA supported projects.

3.5 The UK Government is responsible for fourteen United Kingdom Overseas Territories (UKOTs), which contain 94% of unique, endemic British species.[44] The protection of marine habitats in UKOTs primarily occurs through the ‘Blue Belt Programme’, which seeks to provide protection to over four million square kilometres of the UKOT marine environment.[45] At present, however, it has achieved just over half that goal, through establishing Marine Protection Areas (MPAs), which are areas of ocean reserved by law of other means to protect part or all of the specified area.[46] Through the Blue Belt Programme, MPAs cover 2.2 million square kilometres in UKOTs. The Joint Nature Conservation Committee, the government’s advisory committee, provides advice to government on all offshore MPAs, including what type of MPA and how much protection they should entail, such as the commercial activities which should be restricted within them.[47] The Blue Belt Programme is supported by funding of £20 million up until 2020,[48] but there are no funding commitments for the Blue Belt Programme after 2020. The Government has said, in response to a report by the Environmental Audit Committee earlier in 2019, that it is “working with… delivery support partners to prepare the case for ongoing long-term support to those [UKOTs] who have engaged in the programme”.[49] The Government has indicated that it is “looking very closely at specific areas of funding beyond 2020”, but has confirmed no details.[50] Given the clear evidence that properly managed MPAs have positive conservation benefits[51], the Government should continue pushing to make good on their Blue Belt commitment to protect four million square kilometres of UKOT seas. We recommend the Government commit funding for the Blue Belt Programme at current levels each year beyond 2020 until the full goal of protecting four million square kilometres of UKOT ocean is met.

Economics and biodiversity

Balancing economic activity and growth with conservation:

4.1 ‘Discards’ are fish that are caught that the boat does not have a quota for, so discards them. Since 2013, the EU has gradually introduced a ‘landing obligation’, that requires fishermen to land all fish caught in an effort to reduce wasteful discards. From the start of 2019, all fish that have a TAC applying to them in the UK must be landed under the landing obligation, unless a specific exemption is granted.[52] An alternative approach to TACs to ensure sustainable fishing is the ‘Days at Sea’ method. This limits the number of days that vessels can fish. The UK Government recently committed to “consider a targeted scientific trial using an effort-based regime (‘Days at Sea’) in place of a quota regime for some low impact inshore fisheries.” The Government suggested that ‘Days at Sea’ is only appropriate to some “low impact, inshore fisheries”.[53] Admittedly, there are problems with the ‘Days at Sea’ model. Fishing fleets might simply increase the amount they fish in the days they are allowed, which risks increasing the total amount of fish caught beyond sustainable levels originally set by quotas.[54] The ‘Days at Sea’ model can also incentivise the buying of more powerful boats, to maximise the capacity to catch stock on the permitted days. There is another version of this ‘Days at Sea’ model. The ‘Kilowatt (kW) Days at Sea’ model limits the fishing of a vessel based on its capacity (measured in kWs), as well as how many days at sea it is permitted.[55] This would reduce the incentive to buy more powerful boats that could lead to overfishing. We recommend the Government trial the ‘kW Days at Sea’ model as a fisheries management measure in future trials, alongside the ‘Days at Sea’ trials for low impact, inshore fisheries.

4.2 We need to build a more ‘circular economy’ – in which materials at the end of their service life are recycled and reused to maximise their value. To do this, more products need to be made from recycled content. The UK Government has announced a range of measures to incentivise producers to use recycled content. The 2018 Waste and Resources Strategy introduced a framework for ensuring that producers bear the full net cost of managing end-of-life products, as well as a system of modulated fees to encourage sustainable product design.[56] Most significant, a tax on plastics packaging with less than 30% recycled content was announced in the Autumn Budget in 2018, coming into effect in April 2020.[57] The UK Plastics Pact, launched in 2018, is a collaborative business initiative that aims for an average of 30% recycled content across all plastic packaging by 2025.[58] There is scope to be more ambitious. The Netherlands, for example, has ‘The Plastic Pact NL’ scheme, which sets a recycled content goal of 35%.[59] We recommend that the UK’s plastic packaging tax threshold for recycled content should be set at 35% from 30% as soon as feasible, and this threshold should increase if viable on an annual basis thereafter.

4.3 The Task Force for Climate-related Financial Disclosures (TCFD) promotes the need for financial actors to disclose risks related by climate change in their Environmental, Social and Governance (ESG) reports, which are annual reports many companies publish measuring their sustainability and societal impact.[60] Ultimately, these reports provide more detailed information on climate-related risks to stakeholders such as investors, lenders and insurers. Whilst it is voluntary, the TCFD aims to develop consistent standards on the disclosure of these climate risks. However, changing ‘natural capital’ – which refers to the stock of natural assets including geology, soil, air, water and all living things[61] – also represents risks to financial actors. Already, for instance, Yes Bank analyses and discloses how projects funded through its green bonds – a bond whose proceeds are used to fund environmentally-friendly projects – have positive as well as negative aspects. For solar energy, positive impacts are the generation of non-fossil fuel generated power. But there are some negative impacts on natural capital – such as changes in land use and habitat loss.[62] The United Nations Environment Programme (UNEP)’s Natural Capital Finance Alliance (NCFA), launched in 2012, is a global initiative that seeks to promote the integration of natural capital considerations into financial products and services, as well as considerations of it into financial accounting, disclosure and reporting.[63] Highlighting and reporting the risks posed to natural capital in financial disclosures would allow key stakeholders of financial actors – investors, lenders and insurers – to better understand their potential impacts on nature, and thereby be able to better seek ways to minimise the threats posed to natural capital associated with their activities. We recommend establishing a task force to promote and introduce standards on financial disclosures on natural capital for financial actors, similar to the TCFD.

Pairing nature-based solutions to climate change with biodiversity

Nature-based solutions for climate and biodiversity goals:

5.1 Trees act as a shelter for wildlife, prevent soil erosion, increase soil fertility, purify our waterways, combat air pollution, provide timber, alleviate flood risk, deliver benefits for human mental health, and increase biodiversity.[64] The ability of trees to sequester carbon from the atmosphere, once all available cost-effective decarbonisation technologies have been deployed, also makes them one of the most effective tools in deeper decarbonisation. The Committee on Climate Change (CCC) has suggested that afforestation efforts must double in the 2020s, and triple in the 2030s (to 27,000 hectares) in order to keep emission reductions on target with the UK’s growing population.[65] The CCC cite the population growth forecast of an additional nine million people by 2050 as a need to combat increasing emissions.[66] In response, in their 2019 election manifesto, the Conservative Party pledged to invest an additional £640 million in nature-based solutions as part of their newly unveiled Nature for Climate fund.[67] Through this, they aim to plant 30 million trees a year by 2025.[68] However, predicted population growth rates can change over time, as can economic growth and its associated levels of emissions – particularly through future technologies which cannot be accounted for presently. We recommend regularly reviewing and, if necessary, updating, the UK’s afforestation target so it is line with trends in population growth and decarbonisation. This review should be led by the CCC and the Forestry Commission, in consultation with other relevant organsiations, on a five-yearly basis.

5.2 The Forestry Commission is the government department responsible for expanding, protecting, and promoting woodlands. The Forestry Commission does not have a programme to engage young people in afforestation and conservation. The Government’s afforestation targets are an opportunity to engage young people in conservation. Currently, there are 3,448 state secondary schools in the UK.[69] Given the next generation will be the custodians of our environment, it is important that more young people are involved in learning about and conducting conservation. We recommend that every state secondary school in the country should plant and name an area of trees to support the government’s new afforestation target. The school should be granted funding from government to take a selection of pupils on a trip to learn about and do the tree-planting. The location of the tree planting should be decided in conjunction with Forestry Commission, who are responsible for tree-planting targets.

About Bright Blue

Bright Blue is an independent think tank that champions liberal conservatism. Our work is guided by five research themes: social reform; immigration and integration; ageing society; green conservatism; and human rights. We were shortlisted for the 2016, 2017 and 2018 and 2019 UK social policy think tank of the year and UK environment and energy think tank of the year in the prestigious Prospect Magazine annual awards.

For more information, contact patrick@brightblue.org.uk

27 August 2020