Biodiversity and Ecosystems inquiry by the Environmental Audit Committee

Written evidence submitted by The Wildlife Trusts


The Wildlife Trusts (TWT) is a grassroots movement of people from a wide range of backgrounds and all walks of life, who share a set of common beliefs. We are the UK’s largest people-powered environmental organisation working for nature’s recovery on land and at sea. There are 46 individual Wildlife Trusts covering the whole of the UK, the Isle of Man and Alderney.  Together, The Wildlife Trusts have more than 800,000 members, 2,000 staff and 600 trustees. We look after more than 2,300 nature reserves, covering more than 98,500 ha, and operate more than 100 visitor and education centres.  We welcome this opportunity to submit evidence to the Environmental Audit Committee’s inquiry on Biodiversity and Ecosystems.


We are facing major environmental crises – climate change and biodiversity loss. The UK is now one of the most nature-depleted countries in the world. For too long policies have failed to recognise the critical role nature plays to our health, society and economy.

To bring about nature’s recovery, nature conservation in the UK urgently needs to enter a new era, in which the value and benefits of a healthy, wildlife-rich natural word are more widely recognised and reflected in the decisions that government, businesses and other organisations make.

Conserving nature – protecting the wild places and nature that remain – is not enough; more must be done to restore the abundance of nature, restore ecosystem processes, and reverse the UK’s status as one of the most nature-depleted countries.

To achieve this, The Wildlife Trusts want to see active recovery for wildlife happening across at least 30% of our land and sea by 2030 - 30/30. Our vision is for 30% of land to be connected and protected in a Nature Recovery Network, which should act as a framework within which decisions about housing, infrastructure, land management and conservation can all take place, and guiding investment in nature to the places where it will have the most effect. A network for recovery is based on the principles set out in the Lawton Review - that there is more, better, bigger and more joined up space for nature.

This should be accompanied by ambitious, legally binding, and enforceable targets for nature’s recovery enshrined in the Environment Bill and enforced by a strong, independent Office for Environmental Protection.

Q1: The state of biodiversity:

The Government needs to significantly improve on monitoring the impact of UK activities on biodiversity.  We know we are facing an ecological crisis and urgently need to address and secure nature’s recovery and increase the level of biodiversity across the UK.  However, it is not currently possible to know whether priority species are in decline.  According to the UK Biodiversity Indicators 2019, of the 2,890 species on the combined priority species list, just 214 had sufficient quantitative time series of relative species abundance to be included in the biodiversity indicator[1].

In January 2018, the Government published the 25 Year Environment Plan (25YEP).  This was followed in May 2019 by the Outcome Indicator Framework which contains 66 indicators arranged into ten themes.  This is intended to be a comprehensive set of indicators describing environmental change that relates to the ten goals within the 25 Year Environment Plan.  In May 2020, Defra published their 2020 Outcome Indicator Framework report[2] to provide an update on the indicators and their development.  Two years on from the publication of the 25YEP and Defra is still only able to provide data, and measure progress, against 38 of the 66 indicators.  Many of the indicators are still in development including those which would tell us useful information about the state of the nation’s biodiversity.

The research and evidence that is often quoted when referring to the state of biodiversity within the UK comes from the State of Nature Reports[3].  Data from a partnership of 50 conservation organisations is used to produce these reports, which provide an overview of how the UK’s wildlife is faring and a consideration of the pressures acting on nature.  If we want to turn around nature’s decline, we urgently need to address these pressures in a coordinated and unified approach. 

In 2011, the Government published Biodiversity 2020: A strategy for England’s wildlife and ecosystem services[4]Outcome 1a of the Strategy, to be achieved by the end of 2020, is: Better wildlife habitats with 90% of priority habitats in favourable or recovering condition and at least 50% of SSSIs in favourable condition, while maintaining at least 95% in favourable or recovering condition.  As of 6 September 2020, just 38.1% of England’s Sites of Special Scientific Interest (SSSIs) are in favourable condition with 91.9% in favourable or unfavourable recovering.  The target will be missed but, perhaps more worryingly, 36.6% of SSSIs were in favourable condition in 2011.  This means that in nearly ten years, just 1.5% (~15,000ha) has improved in condition.

For many years, Natural England (NE) has not had sufficient resources to monitor and assess the condition of SSSIs.  Some places have not been assessed in 15 years and in 2017 just 3% of SSSIs (by area) were monitored[5].  This is a major issue and means that wildlife – even in our most important wild places – is under threat.  This financial year, Natural England has received a small increase in their budget with some of the funding being used for improving the monitoring of SSSIs.  However, the backlog is immense and the true condition of many SSSIs is now unknown.  This also has an impact on developing appropriate management plans and remedial actions.

In addition, nearly ten years on from the publication of Biodiversity 2020, an action-based proxy measure is still being used to assess progress towards part one of Outcome 1a (90% of priority habitats in favourable or recovering condition).  Priority habitat is ‘counted’ if it is within an agri-environment scheme (or similar) and part of a selection of ‘beneficial management’ options.  However, an action-based approach assumes that the management plan will a) be implemented and b) create and/or restore that condition of wildlife-rich habitat. 

Outcome 1b of Biodiversity 2020 is no net loss of priority habitat and an increase in the overall extent of priority habitats by at least 200,000ha.  In July 2019, Natural England reported to the Defra Biodiversity Programme Board that, as of January 2019, 154,000ha of priority habitat had been created (=77% of the target).  However, there is no mechanism to detect loss of habitat and, as reported in the Centre for Ecology and Hydrology’s (CEH) Evaluation of Biodiversity 2020 report[6], “it has not been possible to establish mechanisms to report habitat losses and therefore assess ‘no net loss’”

Lessons need to be learnt from Biodiversity 2020.  The outcomes and targets within this Strategy, whilst partly implementing our international commitments (including the Aichi targets), were designed by government and presented to the NGO community with a request to help them deliver.  However, there was no consultation on the targets, no engagement in the process and no funding or support to help achieve the ambitions.

In August 2020, Defra published a policy paper on Environment Bill – environmental targets[7].  There are some encouraging aspects to the paper that would address some of the above concerns and challenges of monitoring to date. However, it is disappointing that Defra is proposing to stick with action-based targets for habitats. Using the same proxy measures as Biodiversity 2020 would mean no further progress has been made to developing an outcome-based indicator in nearly ten years. 

Each year, Defra and JNCC publish various Biodiversity Indicator reports – on an England and UK level – and year-on-year, the effect is the same – reporting on continuing declines.  Monitoring without remedial action is futile.  Monitoring without tackling the reasons for the decline will not address biodiversity loss.  There is a need for recovery trajectories and milestones so that it is possible to report if positive change is happening, and if not, to understand what needs to be done to get back on the path to nature’s recovery. 

The UK is one of the most nature-depleted countries in the world.  The 2019 State of Nature Report showed that since 1970, 41% of species have seen their populations decrease and one in seven species is at risk of extinction from Great Britain[8]

At an international level, the 2010 Convention on Biological Diversity (CBD) target was “to achieve by 2010 a significant reduction of the current rate of biodiversity loss[9]At the Nayoga UN Biodiversity Summit in 2010, a Mission was agreed that we “Take effective and urgent action to halt the loss of biodiversity in order to ensure that by 2020 ecosystems are resilient and continue to provide essential services, thereby securing the planet’s variety of life, and contributing to human well-being, and poverty eradication[10]”.  To deliver this ambition, the CBD Parties agreed to a set of strategic goals and targets – the Aichi targets.  For the UK, there has been insufficient progress towards these goals and neither they, nor the UK targets that reflected them, have been achieved. 

For England, Biodiversity 2020 set out, in Annex C, how the various actions and outcomes from the Strategy linked to and would deliver the Aichi Targets.  In fact, a number of the Biodiversity 2020 outcomes were almost a direct translation of the Aichi Targets.

The CEH Evaluation of Biodiversity 2020 report[11], noted that “Whilst major knowledge gaps remain regarding the number and trends of threatened species there is evidence to show ongoing decline” and “there has been insufficient progress to improve the overall status of wildlife in England and so to meet the outcome”. 

At a UK level, JNCC produces a national report on progress towards the Aichi Targets.  Their Sixth National Report was published in May 2019[12].  It sets out a range of measures taken to contribute to the implementation of the Aichi targets.  For a number of these, they report that the measure has been partially effective.  They report that just five of the 20 Aichi targets are on track to be achieved but that “there is still more progress required in other areas”. 

It is essential that the UK Government takes a strong leadership role in the negotiations at next year’s CBD to ensure that ambitious new biodiversity targets are set.  Progress over the last ten years suggests little political will or desire to meet even intentionally agreed targets.  If we are serious about nature’s recovery and the need to avoid both an ecological and climate crisis, we need legally binding targets that are underpinned by policy, legislation and financial resourcing to deliver. 

Q2: Evaluating measures to conserve and enhance biodiversity:

The climate and ecological emergency will have a profound impact on our environment and agriculture. One measure of this is the Farmland Bird Index – an index which shows that around 90% of the UK’s corn bunting and turtle doves have been lost since 1970.

The Wildlife Trusts believe that the health of the environment must be at the heart of future agriculture and land management policy – which means designing a new system to incentivise farmers and other land managers to help nature to recover, based on environmental outcomes and public benefits.

The Wildlife Trusts want to see active recovery for wildlife happening across at least 30% of our land and sea by 2030. Our vision is for 30% of land to be connected and protected in a Nature Recovery Network (NRN) which allows nature to thrive once more (see below answer for more detail). ELM is vital to realising this vision - land managers should be supported to improve their land for nature and contribute to a Nature Recovery Network. All the public goods which ELM will pay for should contribute to the 30% by 2030, including its stated aim to deliver ‘thriving plants and wildlife’.

It is disappointing that Defra are still developing the final set of priorities for ELM. The Wildlife Trusts would like to see another consultation for ELM which includes a clear articulation its outcomes with plans for the associated actions and payments to deliver them – including for biodiversity.

ELM – as set out in the 25 Year Environment Plan – will be a key delivery mechanism for the Government’s environmental ambitions. Therefore, ELM objectives should be legally tied to meeting the environmental targets and objectives set through the Environment Bill and Environmental Improvement Plans. Further, there should be a structural connection between the Agriculture and Environment Bills to avoid wider environmental ambitions being undermined, as happened with the Common Agricultural Policy (CAP).

Payment rates in the existing agri-environment scheme, Countryside Stewardship (CS), can be too low to incentivise land managers to join, especially given reporting requirements of CS. Uptake of ELM will only improve if payment rates are competitive, and regulation is enforced. Farmers and other land managers in a new scheme must be better rewarded for the natural capital assets they maintain and the ecosystems services they provide.

ELM should not be viewed as a new ‘agri-environment scheme’. It is the foundation of a new approach to restorative land management that should support wildlife and bring an end to the biodiversity crisis, open up the countryside to the public, underpin more environmentally sustainable food and timber production, and help land management businesses become more sustainable and resilient. It should contribute to net zero and to creating 30% of land for nature’s recovery by 2030.

If done correctly, it should enable farmers to move beyond seeing the environment as a ‘bolt-on’ option to their business to a more holistic approach to food production and land management, recognising the interdependencies between farming and nature, and acknowledging the wider environmental services that can benefit their business and society at large. This can only be done in practical terms if the financial remuneration of ELM reflects the potential profits from a range of alternative practices. ELM should enable some land managers to change what they produce from food to nature. Encouraging and enabling a whole-farm approach should therefore be an overarching objective of ELM, with Tier 1 in particular geared towards making the environment central to every farming and land management business. Some models already exist, such as organic, agroecological and regenerative agriculture. ELM should incorporate and build on these and in doing so, help the farming and land management sector move to a new environmental norm.

There are many measures across different types of farm, holding and landscape which could benefit biodiversity through ELM. The Wildlife Trusts set out our proposals for what ELM should pay for – including biodiversity measures – in our recent consultation response on ELM[13].

Despite successive laws which have tried to protect nature, there has been no let-up in its long-term decline. The Wildlife Trusts have long called for ambitious legislation to secure nature’s recovery, and we welcome the publication of the Environment Bill and its ambition. In particular, we welcome the introduction of Local Nature Recovery Strategies (LNRSs) in the Bill to support the creation of a Nature Recovery Network, but to be successful this legislation will need to be interpreted and delivered with ambition.  We elaborate on the Nature Recovery Network in our response to the following question. 

Local Nature Recovery Strategies should draw many different sectors together to plan how to achieve nature’s recovery locally and, in combination with other mapped environmental information, the Nature Recovery Network maps will form the spatial plan that helps target their activity to contribute to the Network.

The LNRS strategies are to be prepared and published by a responsible authority and are intended to assist local authorities and other public bodies (including regional authorities) in identifying priorities and opportunities for conserving and enhancing nature.  The draft Environment Bill leaves the identification of the Responsible Authority fairly open[14], and therefore the Strategies could in theory be developed at any scale. The Wildlife Trusts believe that Local Nature Recovery Network mapping initiatives and their strategies for delivery would be most effective if they are based on locally-identified need, knowledge, data and thorough consultation with local people and organisations.  The Responsible Authority should be one with longevity, acting over a suitable scale, with democratic accountability.

Local Nature Recovery Network maps need to enable the effective integration of decision making across public sector bodies. If they are to be used to target funding and influence land-use decisions it is vital that there is also a robust consultation process. The maps should be scaleable to local authority areas as this is the geographic sphere for land use planning of development.

Local Nature Recovery Strategies have the capacity to achieve huge value for society, integrating decision making in key areas, such as planning, biodiversity net gain, and ELM, to achieve multiple benefits for people whilst addressing the fundamental problem of reversing the ecological emergency.  But to do this, the duty to use these strategies must be strengthened in the Environment Bill. There should be a much stronger requirement to take the strategies into account in the exercise of public functions, including in the statutory planning system and in spending decisions.

The Wildlife Trusts believe that development should be delivering a biodiversity net gain and are also pleased to see this included in the Bill. The Wildlife Trusts want an approach that is best for biodiversity and leads to genuine and demonstrable gains in the long-term.  We want to see the mitigation hierarchy applied, so that all impacts resulting from the development are properly mitigated and compensated for.  The Environment Bill should be explicit that the mitigation hierarchy is not undermined by biodiversity net gain as it should provide additionality.

We are also concerned that, as currently drafted, the Environment Bill excludes Nationally Significant Infrastructure Projects (NSIPs) and other large-scale infrastructure projects from the net gain requirements. When it comes to development, there must be a level playing field. All national infrastructure projects should deliver biodiversity net gain, as these projects (such as HS2) usually have the greatest impact on wildlife. If done right, biodiversity net gain on projects such as HS2 would deliver huge returns for wildlife and people, putting public money to good use. Furthermore, as currently drafted, newly created habitat, as part of developers’ biodiversity gain requirements, could be destroyed after 30 years. Biodiversity gain habitats must be secured and maintained in perpetuity, or the system could lead to overall losses.

The Nature Recovery Network must form the overarching framework for a number of elements of government policy and legislation. As a spatial vision to enable nature’s recovery it is a vital tool to improve the ecosystems on which society depends. The Nature Recovery Network should provide the spatial framework for delivery of ambitions, commitments and targets set out in the Environment Bill, the 25 Year Environment Plan and the Nature Strategy. It should guide delivery of any policy which has a spatial element and requires activity which may affect the natural environment. 

A Nature Recovery Network is a joined-up system of places, needed to allow nature to recover and thrive. It is a combination of the existing places which have lots of wildlife, and the places where habitats need to be created, to expand these remaining fragments and connect them up so that nature, which has been disastrously damaged, can recover.  To be effective, it must extend across every part of country, including rural areas, coastal sites, cities and towns. 


To create the Nature Recovery Network, we need:

  1. A national framework which sets criteria and guidance for development of Local Nature Recovery Network maps and delivery strategies (i.e. Local Nature Recovery Strategies), to ensure consistent quality and compatibility, so that local maps can be combined to inform any scale of delivery, and add up to a national Nature Recovery Network.
  2. A spatial plan – the Local Nature Recovery Network Maps, developed in partnership, which identify accurately where existing wildlife habitats are now and where they should be in future to sustain a healthy, diverse natural world that is rich in wildlife and brings significant benefit to society. 
  3. Local Nature Recovery Strategies for delivering the Nature Recovery Network, developed and agreed in partnership with local stakeholders, which set out how all parts of central and local government and other key players will target, co-ordinate and integrate regulation, investment and expenditure to achieve nature’s recovery (as set out in the Nature Recovery Network Maps).  The LNRS will need to draw on both the Nature Recovery Network and spatial information on ecosystem services.  This will enable opportunities for the delivery of multiple benefits to be identified, to provide best value for time and money invested. 
  4. A statutory duty to create these maps and plans. All relevant parts of local and national government should play an active part in developing and maintaining these Maps and Plans; to ensure that nature’s recovery delivers the widest possible public benefit and to contribute to the implementation of delivery plans.
  5. All public bodies must be held to account for their part in achieving nature’s recovery.


A Nature Recovery Network would consist of:


Effective delivery of the Nature Recovery Network will require actions to be identified and implemented, for example in England in the form of Local Nature Recovery Strategies as proposed in the Environment Bill.  At present the relationship between Local Nature Recovery Strategies and the Nature Recovery Network is not clearly defined in the draft Environment Bill and neither Defra nor Natural England has published details of how they expect this to work. It is vital that this legislation and subsequent policy and guidance works for nature’s recovery. The Wildlife Trusts can demonstrate practical examples of how the mapping referred to in the components of the Local Nature Recovery Strategy must plan an ecologically coherent network that will truly enable nature’s recovery.

The Environment Bill includes a requirement for Local Nature Recovery Strategies to be produced that cover the whole of England.  Each Local Nature Recovery Strategy will include a map of existing nature ‘assets’ (covering protected sites and wildlife-rich habitats) and will identify key opportunities for enhancement[15].  This, we would argue, is the local Nature Recovery Network which, as set out above, consists of core nature habitats and the opportunities for nature’s recovery. As such, it is envisaged that Local Nature Recovery Strategies will act as delivery mechanisms for the Nature Recovery Network and will place local Nature Recovery Networks on a statutory footing[16].  The Wildlife Trusts don’t think that the whole Nature Recovery Network needs to be statutorily protected but the process of spatial planning for nature does require statutory underpinning. 

There are a plethora of other policies for conservation and enhancement of existing natural habitats and our response focuses on just four not covered in answers to the other questions. 

Local Wildlife Sites

Local Wildlife Sites (LWS) are non-statutory sites but are selected for their substantive nature conservation value. They are defined areas identified and selected for their nature conservation value, based on important, distinctive and threatened habitats and species. They play a critical role by providing essential wildlife refuges in their own right and by acting as stepping stones, corridors and buffer zones to link and protect other site networks and the open spaces in our towns and countryside. Local Wildlife Sites are selected if they meet the locally-agreed criteria, unlike Sites of Special Scientific Interest (SSSIs) which are offered the highest level of statutory protection but which for some habitats are just a representative sample of sites that meet the national standard. As a result, many sites of SSSI quality are not designated and instead are selected as LWS. LWS are recognised across the UK in national planning policies which set out requirements for their protection through local policy and plans. However, these sites are less well known and often underappreciated.  It is important that they are recognised in the proposed planning reforms and any future agri-environment scheme as being important core areas worthy of investment and protection.  As with SSSIs, we also need to ensure there are adequate resources available for managing and monitoring LWS. 

We are pleased to see Local Wildlife Sites included in the list of existing valuable areas to be protected within the Protection Zone proposed in the recently published Planning for the Future White Paper.  However, we have serious concerns about the proposals for categorising land into three groups because this simplification brings the risk of creating a disconnected landscape which fails to properly integrate nature. 

National Parks

Our National Parks are highly valuable natural assets.  They comprise some unique and inspiring landscapes across the UK.  National Parks also make important contributions to our economy and society and are part of our national identity.  They are of huge importance to the people who live and work within them, as well as the many millions who visit for recreation and tourism.  However, our National Parks are designated for their landscape value and not for their biodiversity value.  We believe that they could and should be far better places for wildlife.  There is a perception that because National Parks are considered aesthetically pleasing, they are also good for wildlife, but their designation provides no stronger protection than similar areas in the wider countryside. 

In many cases, National Parks have actually experienced wildlife declines on a par with non-National Park areas. For example, raptor persecution continues in our National Parks; wader populations (e.g. curlew and redshank) continue to decline; and hay meadows continue to be converted into silage fields.  In upland National Parks, intensive land management practices associated with grouse moor management can have negative impacts on some wildlife. 

The National Parks and their economies face a range of current and future challenges, many of which are common to rural or remote rural areas across the country. This means there is a high reliance on farming, forestry and tourism, and associated seasonality of economic activity.  This has resulted in poor profitability of farming systems, particularly upland grazing livestock systems, together with a reliance on public payments and a limited ability for farm businesses to develop and diversify income.  The impact of this is intensification of grazing and other land uses which have led to degradation of habitats and loss of biodiversity. 

By contrast, in and around some of our, usually smaller, lowland National Parks and protected areas, traditional land management is directly threatened by economic drivers on the doorstep of protected areas in the form of development and recreation. This results in inflated land values and increased pressure on sensitive sites and wildlife due to recreation.

The Wildlife Trusts are particularly concerned about the decline of biodiversity in National Parks.  The Campaign for National Parks reported that 75% of Sites of Special Scientific Interest (SSSIs) in English National Parks are in ‘unfavourable condition’ compared to the 61.3% of the total SSSIs in England[17].  The Wildlife Trusts believe that National Parks have failed in their statutory duty to enhance wildlife.

Even though each National Park is different in terms of its condition before designation, they should all be beacons for biodiversity and they should be doing more for wildlife. The evidence currently suggests otherwise.  Previously, we have suggested eight principal changes:

Catchment Based Approach (CaBA)

Catchment Based Approach (CaBA) partnerships (designed around a catchment) are a group of locally-identified stakeholders that work to agree and deliver strategic priorities for their catchment. They have been effective in leading collaborative action and drawing together funding to deliver towards Water Framework Directive (WFD) objectives, but their continued efforts must be underpinned by effective support to also deliver for wider biodiversity which will need to be through a range of mechanisms including targets. The Partnerships can play an important role in the development of LNRS, feeding in priorities for the water environment, but as part of this, CaBA would benefit from a trebling of funding, including for local Catchment Partnerships, and funds provided on a multi-year basis to allow for longer term planning and greater leveraging of matched funding. 

We have the opportunity to build on the solid foundation provided by the WFD and to add in our own national approaches and priorities - which should include a focus on wider freshwater biodiversity, given the precarious state of our freshwater environment. The components of freshwater biodiversity not well catered for via the existing WFD-based framework should be the focus on freshwater targets developed through the Environment Bill and / or new Nature Strategy.  A holistic approach should be taken to consider the needs of not only WFD waterbodies and protected sites, but also priority freshwater and wetland habitats, considering biodiversity across the wider freshwater environment, in line with the principles of the Water Framework Directive.  As part of this, mapping of priority wetland habitats which identifies existing areas of good-quality habitat as well as opportunities for restoration, can identify areas where habitat restoration or recreation will be valuable to support biodiversity delivery as well as creating functional floodplains / coastal habitats that can play a role in flood and coastal erosion risk management.  The complexities of the freshwater environment mean that the spatially planned framework of the Nature Recovery Network will be valuable for identifying where priorities align, and can therefore be used as a framework for the pooling of funding to deliver benefits which would not have been affordable without collaboration.  It will also ensure the strategic and cost-effective enhancement of freshwater biodiversity and the water environment for the benefit of nature and society.  The continued support to Catchment Partnerships, including via a longer-term funding settlement will be required to see the realisation of the full suite of benefits that CaBA can deliver. 

Marine Protected Areas

The UK marine area is a vast resource that is of vital importance to our well-being. Not only does it provide us with valuable environmental, economic, and cultural benefits, it plays a major role in shaping our climate and in sustaining life. As part of the North-East Atlantic, UK seas are some of the most biologically productive marine areas in the world. Furthermore, the UK is on the edge of the coastal shelf which means we have an unusually high variety of habitats and undersea landscapes. These include cold-water reefs, seagrass meadows, kelp forests and sandy, gravelly or muddy sea floors home to millions of shellfish and worms.

The Wildlife Trusts have been actively campaigning for a well-managed ecologically coherent network of Marine Protected Areas (MPAs) in UK seas for decades and were instrumental in passing the Marine and Coastal Access Act 2009 (MCAA).

The MCAA (2009) provided for the establishment of a network of MPAs that: contribute to the conservation or improvement of the marine environment; are representative of the range of features present; and reflect the fact that the conservation of a feature may require the designation of more than one site.

To achieve healthier seas, our MPA network needs to be completed. To this end we have seen significant progress with designations in Secretary of State waters on a national and international level including; 91 Marine Conservation Zones (MCZs), 42 Special Areas of Conservation (SACs), 47 Special Protection Areas (SPAs) and 97 Sites of Special Scientific Interest (SSSIs).

Similarly in Scotland, the Marine Scotland Act (2010) and the UK MCAA (2009) included powers for Scottish Ministers to designate MPAs for nature conservation purposes, of which there are currently 31 in total protecting habitats and species such as maerl beds, coral gardens and common skate sitting among many more SACs, SPA and SSSIs.

In Wales, the Welsh Government continues to work in partnership with its statutory advisors and stakeholders to add offshore sites to the existing 137 MPAs in Welsh inshore waters, while in Northern Ireland, through various existing sites and new MCZs designated under the Marine Act (Northern Ireland) 2013, the network of MPAs in this area now represents 38% of the Northern Ireland inshore region.

However, many MPAs in the UK are not in favourable condition and the Government’s Marine Strategy assessment shows that the marine environment is not in a healthy state. Therefore, it is clear that the current network based on multi-use MPAs (sites protect discrete habitats and species while allowing other sustainable use to continue) needs proper management, monitoring and enforcement to ensure the conservation objectives of these sites are being achieved and to allow the process of recovery to begin in sites already in a degraded or unfavourable state.

In addition to properly managed, monitored and enforced network of MPAs, we also need a suite of Highly Protected Marine Areas (HPMAs) which would offer the gold standard of protection for areas of our seas. HPMAs would offer the strictest possible protections for the marine environment by removing all damaging activities across the whole of the site, giving nature the best chance of recovery. Furthermore, appropriate scientific and ecological monitoring of HPMAs would allow us to document what recovery at sea looks like, enabling us to determine which management strategies are most successful and in turn help inform decisions in relation to the broader MPA network.

The network of MPAs around the UK will go a long way in helping to protect and conserve important marine habitats and wildlife for the future and deliver benefits more effectively than unrelated individual MPAs. The network is essential not only to stem the alarming decline in marine habitats and species but also to ensure that the social and economic benefits derived from marine goods and services can be realised for generations to come.

Q3: Co-ordination of UK environmental policy:

The climate crisis and the nature crisis are inseparable and we cannot successfully tackle one without tackling the other.  Equally, we need to recognise that these elements – biodiversity, air, soil and water - are also all interconnected.  In addition to considering how biodiversity can help achieve the other goals in the 25 Year Environment Plan, we also need to consider how meeting air, soil and water quality objectives support nature’s recovery and addressing biodiversity loss. 

In terms of water quality, managing the freshwater environment is a tricky balance – we expect our waters to support wildlife, provide drinking water supplies, take away our wastewater, and avoid flooding our homes.  However, at the moment, in winter, downpours wash farmland soils, agricultural chemicals and urban pollutants into our watercourses and high flows erode riverbanks and threaten homes. In summer, the lack of rainfall to replenish our waters lays bare how much we extract to supply homes and businesses, leaving some rivers running dry.  Our rivers, lakes and wetlands are struggling.

There are targets in place to put rivers, lakes, estuaries, coastal waters and the groundwaters that support them into ‘Good Status’ – a near-natural state.  But, only 16% of England’s waters currently achieve this standard[19].  If we are to make more significant progress towards the targets, there needs to be a step-change in how we manage the water environment.  We have the opportunity to build on the solid foundation provided by the Water Framework Directive (WFD). However, the Environment Bill currently includes a worrying clause that could give the Westminster government the powers to amend difficult targets or the way they are measured. This is unacceptable. Instead, we need to add in our own national approaches and priorities - which should include a focus on wider freshwater biodiversity, given the precarious state of our freshwater environment.

Principally, improving water management requires far better integration of water objectives into other policy areas including biodiversity but particularly agriculture and land use planning.  Action to tackle water pollution, regulate flows and manage invasive species will support biodiversity recovery and reduce the vulnerability of the water environment to the impacts of climate change.  Action by the water industry should move towards the mainstreaming of Nature-based Solutions, which can play a key role in tackling wastewater pollution (e.g. biodiversity-rich SuDS and treatment wetlands) and water resources pressures (e.g. habitat enhancement to provide natural resilience to the impacts of abstraction and drought), whilst also delivering against biodiversity objectives. Spatial planning must prevent development on floodplains, and measures to ensure sustainable land use and management should be supported via ELM to enable our adaptation to the effects of climate change and restore the functionality of some floodplains. Impacts on water quality from a new development should be considered in the early stages of the design process with quantitative assessment and modelling of approaches used to ensure that green and blue infrastructure are effectively integrated into new developments, recognising the role that these measures play in improving water quality as well as providing multiple benefits around biodiversity, greenspace, air quality and health and well-being.

We support the target in the 25 Year Environment Plan for all England’s soils to be sustainably managed by 2030.  However, the recent Defra England Peat Strategy Policy Discussion Document proposes a target to bring “all our peatland into good condition, restoration management or more sustainable management by 2040”.  The target for ‘more’ sustainable management falls short of the 25YEP goal.  Instead, we need to achieve sustainable management by 2030 to lay the ground for achievement of the later ‘good condition’ and ‘restoration management’ components of the target.

Through Environmental Land Management (ELM) we need to invest in the restoration of land so that it can continue to provide us with the public benefits we need, for example, healthy soils, carbon storage, flood and drought management and abundant pollinators (see previous answer on the Environmental Land Management Scheme).  There needs to be a focus on the outcomes that a well-funded, well-designed and well-delivered ELM scheme needs to provide. For example, a range of measures are necessary to achieve healthy soils such as ploughing less often, replacing artificial fertilisers with natural organic matter and ensuring crop rotation and planting catch cover crops.  These outcomes will also have clean air, water quality and climate change benefits as they will help reduce greenhouse gas emissions, reduce runoff, and increase carbon absorption.  Farmers should be paid fully for the costs of management and for going over and above best practice measures.

In terms of peatlands, for investment to provide an economically viable alternative for land managers, damaging but lucrative land management practices like overstocking and the burning of grouse moors must be prevented.  This applies regardless of whether the aim of subsequent investment is to achieve biodiversity targets, carbon targets or other public goods.  Income foregone as the basis for determining land management payments is insufficient to fund the scale of restoration required on many badly-damaged peatland sites.  A Government commitment to long-term funding approaches – whether through ELM or specific peatland funds and targeted through the Nature Recovery Network – will be necessary to support peatland delivery. 

Whilst peat has risen up the agenda politically due to its importance as a carbon store / source, we must not focus on carbon at the expense of biodiversity.  Any carbon-focused scheme must also deliver for nature.  Rewetting / maintaining wetness underpins both priorities and will be a key component of management to reduce carbon emissions (e.g. raising water tables, implementing paludiculture) as well as management to restore peatland habitats for biodiversity.  The restoration of hydrological function (encompassing water quality as well as quantity) is necessary to underpin the restoration of peatlands and their characteristic biodiversity.  Wetlands, including peatlands, make up an important part of a connected living landscape and will form a key component of a Nature Recovery Network, needed to allow species to move through the landscape, respond to change and to contribute to nature’s recovery

In both climate and biodiversity terms, the need to cease peat extraction is clear, and the voluntary approach to transitioning has seen targets missed (e.g. the voluntary target for retail suppliers in England to be peat free by 2020).  There is now an urgent need to legislate, preventing any remaining peat extraction in the UK as well as banning the use of peat sourced from abroad.  A ban on burning on all peatlands also needs to be brought forward to protect peatland biodiversity and carbon stores.  The CCC recommended that Defra ban rotational burning on peatland as a contribution towards zero carbon from land management (which goes beyond the ban only on protected sites as proposed by the Government). 

The Wildlife Trusts are calling for at least 30% of land and sea to be protected, connected and well-managed for nature by 2030.  Especially in lowland environments, at 30% habitat patches are sufficiently connected for many species to move easily between them, enabling their populations to be more resilient to environmental pressures including climate change.  We believe that the 30% of more, bigger, better, joined land for nature should be a mixture of internationally, nationally and locally protected sites, plus a more diffuse array of other habitat for nature – hedges, field borders, ponds, copses, verges and places for people that are also managed for nature. 

We need more of our land managed for nature.  At the forthcoming UN negotiations, the UK Government should show leadership and push for a 30 by 30 target. 

As mentioned above, it is also important that the UK Government then shows leadership domestically and sets legally-binding milestones and targets so that this time we do meet our international commitments.  For too long, the UK has made insufficient progress and has simply allowed our international commitments to go unmet.  This must change if the Government is to meet its stated ambition to leave the environment in a better state for the next generation. 

Q4: Economics and biodiversity:

For too long policies have failed to recognise the critical role nature plays to our health, society and economy. The gulf between the demands we are putting on nature for economic growth and its ability to supply those demands is too large. The interim report of the Dasgupta Review highlights that a much more integrated approach to measuring economic success is necessary, recognising the critical inter-dependence of a successful economic approach and the role of biodiversity and nature.

Since the 2013 Ecosystems Market Task Force report there has been a growing recognition of the importance of investing in our natural assets and the opportunity associated with a nature-based economy.  Subsequently this thinking has informed the 25 Year Plan for the Environment, the Clean Growth Strategy and the Industrial Strategy.  All these documents acknowledge the need to consider our natural assets, but progress has been slow. 

As central and local government, businesses and the third sector begin to plan for the recovery from Covid-19, we must recognise the risks of a traditional approach to economic recovery and instead take opportunities to embed a nature-based solutions approach within economic recovery decision making. Such an approach will not only increase our resilience to future economic and environmental shocks but will also provide productive opportunities, space for innovation and new jobs and skills. 


Investment models such as Surrey Wildlife Trust’s ‘Naturally Richer’ project demonstrate a new approach which places nature’s recovery at the heart of the local economy. This project provides a model for the way in which strategic investment in the area’s natural assets supports sustainable social, economic, and environmental prosperity. It will enhance natural assets between key strategic growth areas with a focus on delivering a Nature Recovery Network. A £428,000 investment by the Coast to Capital (C2C) Local Enterprise Partnership has made the project possible and is the first such economic investment in natural assets made.

The development of a nature-based economy will also improve the health and wellbeing of people. The Wildlife Trusts want wildlife and wild places to be an integral part of where people live, travel and work.  The need for wildlife and wild places to help us stay well and to recover from illness – particularly mental ill health and illnesses associated with obesity and loneliness – is becoming urgent.  Today, at least £15 billion a year is being spent on preventable illnesses associated with our lifestyles: 20 million adults in the UK are physically inactive[20] and obesity is on the rise, along with mental ill health, dementia and social isolation.

It is no exaggeration that nature’s recovery would contribute to preventing health and social care problems at scale, as well as reducing the current burden on the NHS.  Evidence shows that just being near nature, even seeing nature through a window, has a good health impact.  Daily contact is linked to better health, reduced levels of chronic stress, reductions in obesity and improved concentration.  The health benefits of living near to nature are greater in poor and disadvantaged communities than in wealthy ones.  Sadly, the most deprived and socially excluded communities rarely live in the greenest areas[21]

The health and social care system can and should help nature to help people.  A change in approach is needed however to help people re-connect with nature where they are.  A natural approach to health and wellbeing is cost-effective and should be playing a more significant role in prevention and treatment within our diverse communities.  The high return on investment for volunteering for nature’s recovery also strengthens the argument for a community-based approach to health.  Research into both Wildlife Trust general volunteering programmes and those activities targeted at individuals with a health or social need and both proved to be excellent valley for money.  A social return on investment analysis found that targeted programmes designed for people with a health or social need showed a return of £6.88 for every £1 invested with the value being generated from health gains such as improved mental wellbeing[22].  For those attending general volunteering programmes, the value was even higher with a return of £8.50 for every £1 invested[23].  We need further investment in targeted programmes and for ‘nature on prescription’ to be standard practice for GPs and NHS mental health providers, supported by specifically allocated NHS funding.

In terms of our towns and cities, we must plan more space for nature.  We believe that nature-rich housing development, designed with environmental sensitivity and green infrastructure at their heart can provide people with easy access to nature where they live and work and deliver multiple social, environmental and economic benefits[24]Local Nature Recovery Network maps should be used in combination with data and maps that show population access to nature, areas of health inequality, information on air quality and other environmental factors that have an impact on health and quality of life. This will identify where investment for nature will also improve access to nature and provide health benefits, increasing the value for time and money invested.  The Local Nature Recovery Strategies should then inform local health plans, such as Joint Strategic Needs Assessments and Public Health reports, incorporating the role of nature to deliver enhanced health, wellbeing and social outcomes.

Q5: Pairing nature-based solutions to climate change with biodiversity:

The most effective nature-based solutions are those with permanence, which respect the local ecology, and which deliver increased connectivity for the benefits of biodiversity. Tree planting has often received a lion’s share of the attention around nature-based solutions to climate change. However, while appropriate tree planting, carried out in the right places and in the right way, can be effective for achieving both climate and biodiversity goals, it must be recognised that tree planting can be harmful or less effective than other solutions. For instance, monoculture plantations are much less beneficial for biodiversity than mixed native woodlands and other habitats, and if the timber is used for biomass this greatly reduces the ‘lifespan’ of the stored carbon. Tree planting has also been known to harm existing habitats, such as species-rich grasslands and peatlands, and may even lead to the release of carbon stored in these habitats.

Woodland creation which is carried out in a sensitive way, favouring semi-natural native woodland, will be the most effective for addressing both climate change and biodiversity objectives. There is also great potential in the UK to restore species-rich grasslands. We have lost over 90% of our meadows in the past 100 years. Restored species-rich grasslands can both act as substantial carbon stores and support abundant wildlife, including pollinators. The UK’s lowland and upland peat areas are also heavily degraded and are releasing the equivalent of 23 million tonnes of CO2 a year. Healthy peatland habitats can support unique wildlife, so rewetting and restoring peatlands can be highly effective for supporting carbon storage and biodiversity. Actions to restore other freshwater wetlands can also be highly effective. These include renaturalisation of river courses and restoration of floodplain systems, as well as the reintroduction of beavers – actions which can deliver wetland habitat that locks up carbon and supports a diverse range of wildlife.

Actions to restore coastal and marine ecosystems must not be overlooked. Managed realignment can create saltmarshes which can lock up more carbon per hectare than other terrestrial habitats, as well as providing habitat for diverse wildlife, including nursery areas for fish. The planting of seagrass meadows will also deliver biodiverse habitat that can lock up carbon at a rapid rate. Wider protections of our marine environment – such as Highly Protected Marine Areas – should be considered as part of a suite of nature-based interventions, as healthy, protected marine ecosystems can absorb vast amounts of carbon.

Cost-effective nature-based solutions should deliver multiple benefits to help mitigate climate change (by increasing the capacity of ecosystems to absorb CO2) and adapt to its consequences (by reducing impacts such as flooding). The delivery of these multiple benefits would ensure cost-effectiveness. In terms of biodiversity, existing indicators of ecological health, such as conservation status and good ecological status (GES), would demonstrate clearly the progress of nature-based solutions on land and at sea. An increase in acreage of land dedicated to nature would also constitute a straightforward and clear indicator of progress, while the delivery of this space in accordance with the Nature Recovery Network and related mapping would ensure this is delivered in the most cost-effective way.

Trade-offs and co-benefits are best considered through comprehensive local consultation and stakeholder engagement. Community engagement can help ensure trade-offs at the local level are fully considered and addressed, while helping deliver projects which provide optimal returns by way of health and wellbeing, biodiversity, accessible greenspace and so forth.

Government policy and programs, including the new Environmental Land Management (ELM) scheme and Nature for Climate Fund, are welcome and will go some way to delivering the necessary funding to support effective nature-based solutions. However, greater investment will be needed from government and the private sector to deliver nature-based solutions at the scale needed to tackle the climate and biodiversity crisis.

Funding and investment can be mobilised by providing clarity and certainty for investors, and by ensuring investment delivers nature-based solutions in the best places for optimal benefits. A Nature Recovery Network will help provide this certainty, by providing the spatial framework for directing effective investment in nature’s recovery and highlighting priority areas for habitat restoration and the delivery of nature-based solutions.

Biodiversity offsetting through net gain will also help deliver more investment in nature-based solutions. However, this will only be fully effective if net gain applies to national infrastructure projects such as HS2, as these are the most damaging and have the most potential to deliver more space for nature.


September 2020








[6] Hawkins C, et al. (2019) Evaluation of Biodiversity 2020.


[8] State of Nature Partnership (2019) State of Nature 2019.



[11] Hawkins C, et al. (2019) Evaluation of Biodiversity 2020.

[12] JNCC. 2019. Sixth National Report to the United Nations Convention on Biological Diversity: United Kingdom of Great Britain and Northern Ireland. JNCC, Peterborough

[13] (see pages 10-17)

[14] A local or unitary authority, Mayor of London, National Park Authority, the Broads Authority or Natural England

[15] Environment Bill 2020 Policy Statement

[16] The explanatory notes to the Environment Bill state that ‘Local Nature Recovery Strategies will… support the delivery of a Nature Recovery Network by acting as a key tool to help local partners better direct investment and action that improves, creates and conserves wildlife-rich habitat’ and that ‘LRNSs will put spatial planning for nature on a statutory footing’.

[17] Campaign for National Parks (2018) Raising the bar: improving nature in our National Parks.

[18] National Park Authorities can do much to reconcile public enjoyment with the preservation of natural beauty by good planning and management and the main emphasis must continue to be on this approach wherever possible. But even so, there will be situations where the two purposes are irreconcilable... Where this happens, priority must be given to the conservation of natural beauty." (Lord Sandford, 1974. Report of the National Parks Policy Review Committee. (Sandford Report). London: HMSO.)

[19] “Only 16% of England’s groundwater, rivers, lakes, estuaries and seas are close to their natural state” - River basin planning: Challenges and Choices consultation Environment Agency 2019.

[20] British Heart Foundation – Physical Inactivity and Sedentary Behaviour Report (2017)

[21] Mitchell and Popham (2008) - Effect of exposure to natural environment on health inequalities: an observational population study - The Lancet 372 (9650): pp 1655-1660

[22] Leeds Beckett University and the University of Essex (2019) A Natural Health Service

[23] Leeds Beckett University and the University of Essex (2019) A Natural Health Service