As a water company, we recognise our dependency on the natural environment for the services that we provide in particular in terms of water quality and quantity and climate regulation, but also with respect to biodiversity.
Through our role as an anchor organisation in Yorkshire, we have a longstanding history of working closely with partners and stakeholders to deliver programmes of work that support biodiversity in our region, and we have referenced a number of those programmes in our response to this Inquiry. These programmes include extensive engagement with the agriculture sector, helping to restore our important upland landscapes, as well as promoting more sustainable land management practices in the lowlands. Whilst our main focus for this work has historically been water quality, we recognise the other benefits that these programmes provide, which include enhancing biodiversity as well as capturing carbon and contributing to reduced flood risk.
As Yorkshire’s second largest landowner, we recognise the role that we have to play in leading by example, and our innovative Beyond Nature programme working closely with our tenants to management our land for multiple benefits, including raising livestock, providing a home for nature, creating spaces for recreation, storing thousands of tonnes of carbon, and contributing to natural flood management, is one example of where we are doing this.
Another example of our innovative approach is through the use of the six capitals, both strategically and tactically, to be more resilient and sustainable by improving our understanding and management of economic, environmental and social priorities. The six capitals represent the resources on which an organisation relies and impacts, both positively and negatively. Having developed our six capitals approach, we are now applying the concept through more and more of our decision-making processes with growing influence over our operational activities and strategic direction.
Finally, our formal regulatory commitments, made through the Water Industry National Environment Programme (WINEP) and many of our Performance Commitments (PCs), provide additional context to the importance that we place on biodiversity. Examples of the latter which are relevant to the AMP7 period (2020 to 2025) including Working With Others, Invasive Species Pathway Management Plans, Length of River Improved, Integrated Catchment Management and Land Conserved & Enhanced.
Government funded monitoring appears to be concentrated primarily through Natural England and focussed on species and sites that are legally protected for conservation reasons, rather than broad scale monitoring of the impacts of UK activities on biodiversity more generally. Further, Government monitoring often appears to be focused on understanding the health of an ecosystem at a snapshot in time and making large inferences about condition trajectory from this. In addition, whilst use of https://data.gov.uk/ has improved in recent years, Government funded monitoring information is still not often readily accessible. This limits the ability to use such monitoring information in attributing causation to observed impacts.
However, Government benefits from an extensive legacy of monitoring in the UK and our overseas territories, often led by wildlife charities, naturalists and associated organisations, including data collected by organisations such as water companies (for example, surveys of our own estate). Whilst not perfect, already good systems for data validation and exchange exist, such as the National Biodiversity Network (NBN) and the Association of Local Environmental Records Centres. Particularly with species data, Government reports often rely on this monitoring.
Going forward, therefore, it is essential that monitoring is funded and resourced properly. Whilst a part of this needs to be better resourcing for NE, in our view funding needs to be broader than just NE and should allow for continued and increased use of ‘citizen science’ data. Funded properly, organisations like the NBN can validate and disseminate this data, which is then readily accessible to a wide range of individuals and organisations, including Government, NE, EA, etc. Further, whilst it is important to monitor protected sites and species because they are generally endangered, it should also be recognised that such sites and species rely on broader ecosystems for survival. It is equally important, therefore, that future species and non-protected habitats targets (and by extension, monitoring) reflect this and look at general diversity as well as specific protected habitats and species.
More broadly, we support the general approach and ambition of Defra, the Natural Capital Committee and the Office for National Statistics in the development of annual national natural capital accounts and biodiversity net gain to help direct and grow resources to better protect and restore biodiversity. We have developed our own natural (and six) capital accounts to help shape more effective decision-making, already enabling the transformation of our land strategy and various innovative land management programmes. We would welcome the opportunity to share more of our approach and learning.
YW response (nil)
The major pressures on nature in the UK are already highlighted as the 6 key areas mentioned in the introduction to this consultation. Progress on the 25-year plan, and future policies and strategies should pay meaningful attention to understanding the impact of these pressures and their interactions, to help develop prioritised solutions, much as the Environment Agency’s River Basin Management Plan process does for Reasons for Not Achieving Good in a waterbody.
Priority should be given to targeting areas of biggest overall social gain that deliver carbon, water, wellbeing and wildlife benefits. Well-developed and evidenced techniques are shown to secure complementary benefits and a substantial return on investment for society, for example in the restoration and protection of peatlands. Escalation of these approaches would make a substantial contribution to biodiversity, climate and flood resilience priorities. Funding should be focused on producing meaningful outcomes for biodiversity and not simply in attempting to perpetuate an anthropogenic construct of what a landscape should be.
As stated in our response to the previous question, the major pressures on nature in the UK are already highlighted as the 6 key areas mentioned in the introduction to this consultation. Developing prioritised solutions to these pressures and their actions, as we recommended in our response to the previous question, will help to target ELMs in a way that maintains and improves biodiversity.
However, prior to full developing solutions, it is important to understand the problem; consequently, gaining greater understanding of the baseline environmental performance of land would provide a starting point for measuring improvements.
One specific example would be in measuring soil organic matter, which provides multiple benefits including carbon capture and water retention (providing resilience against both floods and periods of drier weather); increasing soil organic matter by 1% per hectare allows that same area of farmland to absorb an additional 235 tonnes of water, over and above what is already being retained. Schemes should encourage minimum soil disturbance where practicable and move towards farming practices that ensure the soil is always covered. This could be through the proactive sowing of intercrop (spatially and temporally) cover crops and/or through permanent grass lays incorporated into crop rotations. Through our innovative landscape scale collaboration with the food and drink supply chain (https://sustainablelandscapes.uk.com/), we have demonstrated that a range of biodiversity objectives (increased worm populations or farmland birds for example) can be delivered whilst at the same time delivering more sustainable; profitable and resilient food production. It is also possible through this approach to deliver carbon neutral or even carbon negative crops.
We would be happy to develop this conversation with Defra and host a visit to one of our pilot farms to see this approach in action.
Alternative land use may improve biodiversity, but it is also feasible to combine outcomes through more creative cultivations rather than focussing purely at an either / or approach. Companion and cover cropping; beetle banks and agro-forestry are examples of such practices, and their use should be further encouraged.
Through programmes including the Yorkshire Peat Partnership (https://www.yppartnership.org.uk/) and Moors for the Future (https://www.moorsforthefuture.org.uk/), we and our customers have helped to fund significant investment into the uplands (blanket bog) which are internationally important habitats for wading birds in particular. Wetter moors are more resilient to a changing climate, and also to the effects of wildfires, and continuing to invest in these valuable landscapes will help to make them more resilient to this increasing threat. They also are more abundant in invertebrates which are an important food source. Along with extensive programmes of rewetting we are also inoculating the moors with peat forming sphagnum species, which are important in their own right. Finally, it is important to recognise that our moors are managed habitats, and a failure to recognise this management, or policies which make moorland management unviable, could lead to a reduction in the biodiversity they currently deliver as well as increasing threat from wildfire and climate change.
Our innovative “Beyond Nature” programme (https://www.yorkshirewater.com/beyond-nature) is working well in this regard. The programme helps our tenant farmers use their land for raising livestock, whilst also providing a home for nature, creating spaces for recreation, sequestering carbon, and contributing to natural flood management. Since 2016, we have been working with our farm tenants to get them involved in the programme and we currently have 5,000 hectares of land signed up across 9 farms. Such programmes could be implemented more widely with more funding through ELMS or similar mechanisms.
We welcome the changes proposed in the Environment Bill around Biodiversity Net Gain, both as a ‘developer’ and a landowner. Whilst much of our development impact is Permitted Development and, as such, falls outside the requirement for mandatory net gain as proposed in the Bill, the existence of a standardised metric and framework for delivery helps assist in delivering large scale positive benefits for biodiversity. We are continuing to work with stakeholders and partners to understand the implications of this, hosting a Yorkshire BNG workshop for all the Local Authorities in our operational area, and starting pilot case studies working on both a bottom up (with local farm groups and Councils across the South Pennines) and top down (working with commercial providers) approach.
We believe that biodiversity net gain must be targeted at an ecologically coherent scale, and the Government will only be able to maximise the benefit to biodiversity by encouraging Local Authorities to apply BNG at a landscape or catchment scale, rather than at a political ward scale.
We do have a concern that the aquatic environment is often overlooked, by government policy and also Planning application/CIEEM PEA Assessments. Often assessments go into detail on the species composition of terrestrial habitats, with aquatic simply clumped as ‘river’. For example, within the Biodiversity Net Gain DEFRA metric, assessing the condition of the aquatic environment is specified as a far more specialist activity than a terrestrial assessment; this is likely to lead to an under-representation of aquatic habitats within net gain improvements.
One arising issue is that a patchwork of these networks is already developing, far in advance of Natural England’s decision-making timescales. Already local networks are being set up in Yorkshire, whilst Natural England has only recently started consulting on what pilot sites for these may look like – NE needs to be more nimble. There needs to be a clear link to Local Nature Recovery Strategies being developed by Councils, but networks also need to be based on an ecologically coherent scale, reflecting a catchment or landscape as a minimum; LNRS’s can then do the detail.
NE states part of their role will be in establishing partnerships to deliver this. However, it may be more effective and more efficient to target efforts at providing tools and targets to support the many partnerships that already exist – including those that Yorkshire Water is already working with, as such upland partnerships referenced previously, or our strategic partnership with the National Trust. NRN’s will need to have bottom up support and drive to really work.
We would encourage the Government and Natural England to learn lessons from the CaBA Catchment Partnerships. Whilst in Yorkshire this is not an area where Natural England have a significant engagement, the Partnerships help provide meaningful and long lasting outcomes for our rivers and catchments, and the nature of the Partnership between regulatory, NGO and private companies, means they are generally flexible and quick to adapt to changing conditions and drivers as well as delivering outcomes far in excess of individual partners’ contributions. This is something that Natural England is not presently able to evidence. The success of many of the Yorkshire Catchment Partnerships has led to us joining with the Environment Agency to provide core funding to a number of Catchment Partnership hosts, to further develop their operational resilience and catalyse their work. The Government should encourage Natural England to act as a facilitator in strengthening existing partnerships, rather than acting as a break on the process by attempting to establish new top down partnerships themselves.
Present government policies are often reactive, and limited and complex funding mechanisms often lead to perverse incentives. For example in the recent Water Environment Grant funding offered by the Environment Agency and Natural England for projects to benefit biodiversity, projects could only target invasive species (one of the 6 key pressures on biodiversity), where invasive species were shown to be an extensive problem; funding was not permitted to target small scale outbreaks prior to them becoming a problem. This is in direct contradiction with the GB Invasive Non Native Species Strategy which sensibly targets biosecurity and early intervention above attempted management of widespread species.
Most relevant to YW, UK policy has focused on cleaning up our waterways and this has been a good thing. However, there needs to be a change in policy in the following areas:
Within the 25 year plan, Government has set water quality objectives around reaching or exceeding objectives for rivers, lakes, coastal and ground waters that are specially protected, whether for biodiversity or drinking water as per River Basin Management Plans. We recognise that restoring biodiversity and ecosystems is a fundamental part of this, and continue to work closely with catchment stakeholders on projects to help deliver resilient rivers, with sufficient connectivity and habitat heterogeneity to adapt and co-exist with anthropogenic use.
One example of this is where we are working with the Yorkshire Wildlife Trust on river restoration projects in some of the country’s most northerly chalk streams, to help ensure that water quality objectives can be met as well as reducing sediment input and the associated water treatment costs we would otherwise be required to fund.
Another example is the Humber project, which we are delivering in through the Sustainable Landscapes partnership (see response to ELMs questions, above). This project is demonstrating how multiple objectives – related to biodiversity and ecosystems, but also other sustainability metrics including those related to business sustainability the rural economy – can be delivered through changing farming practices. We are co-funding this programme because of the water quality and flood benefits that it will provide. However, others in the supply chain are also funding and farmers benefit too. Biodiversity benefits are multiple, including pollinators from cover crops, beetle banks for natural slug predator control, worms, soil biota, food source for farming birds, etc (https://sustainablelandscapes.uk.com/news/press-release-collaborative-farm-based-environmental-project-launched-in-east-yorkshire-could-significantly-cut-co2-levels/).
YW response (nil)
YW response (nil)
We are successfully applying a six capitals approach, both strategically and tactically, to be more resilient and sustainable by improving our understanding and management of economic, environmental and social priorities.
The six capitals are Financial, Manufactured, Natural, Social, Human and Intellectual; these represent the resources on which an organisation relies and impacts, both positively and negatively. By going beyond the traditional focus on financial and manufactured capital, an organisation can consider, measure and manage more of what really matters to people – health, wellbeing and prosperity.
Having developed our six capitals approach, we are now applying the concept through more and more of our decision-making processes with growing influence over our operational activities and strategic direction. For example, we have and continue to use this approach to change the following so far:
In short, the more the we work with the six capitals, the more opportunities we find and continue to develop and embed. A range of case studies and methodologies are published at www.yorkshirewater.com/capitals.
More widely, the traditional focus on Gross Value Added (GVA) as an indicator of the nation’s prosperity is outdated and should be replaced by a focus on what truly matters to people, their health and wellbeing and the state of the resources we fundamentally rely on (air, water, climate, finite resources, skills, etc)
Pairing nature-based solutions to climate change with biodiversity:
There are multiple nature-based solutions that can help to achieve both climate and biodiversity goals. Examples that are relevant to us include:
Recognising that there are multiple different approaches that can be taken it is important that a balanced approach to nature-based solutions is adopted. There is no ‘one size fits all’ response to identifying which nature based solutions are more effective.
As with solution-types, there are multiple different indicators that could be used. We have listed some suggestions below and we would also point you towards the wide range of measures that are included in our latest Six Capital accounts, soon to be published at www.yorkshirewater.com/capitals. We would also note that, from a water industry perspective, it is worth consulting with Ofwat on this issue, as they have recently consulted on the potential for including metrics for nature-based solutions in future water company regulatory reporting.
Example indicators include:
One essential aspect of funding for nature based solutions is an understanding that they take time to mature and to deliver their full benefit. Therefore a long-term commitment is required, and, in addition, stability of the regulatory and policy environment is also important. This needs to be reflected into schemes that may help to fund nature based solutions, such as ELMs.
With regards to encouraging funding of nature based solutions, we would welcome greater flexibility in the regulatory regime to allow water companies to use NBS more. Water companies are well placed to coordinate multi-agency approaches and manage projects with delivery partners - the only real limiting factor is the available funding which ELMS, Net Gain and other mechanisms could help grow.
In addition, the contribution of markets to encouraging funding from the private sector should be considered, for example by encouraging and incentivising financially the storage of carbon emissions through better land use. Ecosystem services and nature based solutions are currently not working at the pace required to tackle climate change goals in the UK. This can be shown in relation to the barriers and difficulties in developing a solution that can then produce a saleable carbon off set, to enable an organisation to buy or sell it to help facilitate carbon reduction.
For carbon specifically, the two main vehicles that do enable this in the UK, at present, are the woodland and peatland carbon code. As of 11th June 2020 the predicted carbon sequestrated through woodland carbon code projects in England was 711 ktCO2e, over their hundred year life cycle. Given that in order to be carbon neutral via off setting in 2019/20 Yorkshire Water would need to purchase 83 ktCO2e or over 10% of the total for England, it shows the need to accelerate the scale and type of off set available from nature based solutions so all companies can use UK based high quality off sets.
There could be largescale opportunities in soil restoration, sea grass. However, projects would need to be verified and registered through processes such as the “Verified carbon standard”, these schemes are complex and hard to apply to with significant start up costs in terms of time and money. This can act as a barrier for smaller projects. While it is vital for schemes to be verified to high standards and in relation to obtaining any financial or carbon value this is also a major barrier.
This lack of ability for companies to develop and/or procure high quality off sets based in the UK is a missed opportunity and should be resolved as soon as possible.
We believe there are several solutions or steps in producing a process and market for high quality carbon off sets and a market for these which encourages more sustainable land use. We believe the introduction of regional carbon markets would be required quickly and at scale. Products need to be created so a cost effective market can be developed and any inconsistencies or weaknesses can be managed out. This system should allow wider nature based solutions to be used to create off sets and a viable UK carbon market for people to buy, sell and trade as required, this in itself would encourage the development of new and innovative solutions that could fed into the market.
A regional market supported by key landowners, anchor institutions, local and regional government to ensure governance is vital, in this process and Yorkshire Water has already made steps to start the process of working together with stakeholders to see if a regional carbon market could be developed. Best practice in regional markets could be shared to create regional markets which can also trade between each other to produce a national solution. We believe this would be a more effective and timely solution than trying to produce a single national funding/market mechanism.
Going beyond the carbon market, ultimately the market could cover biodiversity offsetting and ecosystem services more widely; combined with biodiversity net gain and NELMS, this could provide a good source of funding for environmental restoration.
Finally, we would note the importance of working in partnership and how this can result in leveraging significant additional funding that might not be available if organisations work in isolation. For example, through the AMP6 period, 2015 to 2020, we delivered 43 projects against our ‘Working with others’ Performance commitment; these projects cost us and our customers some £5.2m but, by working closely with partners, a further £34m of additional funding was leveraged, either directly from partners of from other sources such as the EU and Heritage Lottery Fund.