The National Biodiversity Network Trust (the NBN Trust), founded as an independent charity in 2000, champions the collection and sharing of UK biodiversity data to make it available for use to inform wise policy and planning decisions, producing robust evidence based research and engaging everyone from school children to politicians with the UK’s natural world. The Trust was established to oversee and facilitate the development of the National Biodiversity Network (NBN). The NBN is the UK’s largest partnership for nature, comprising of over 190 member organisations. Our 125 data partners work together, gathering, verifying and sharing biodiversity information from across the UK. Many of our members have supported the collection of biodiversity data for decades and contribute to the world picture of biodiversity through contributions to the Global Biodiversity Information Forum (GBIF) and internationally acclaimed research and conservation projects.


This submission is on behalf of the National Biodiversity Network Trust.

We have only responded to the questions for which we have the most relevant knowledge and experience.

The state of biodiversity:

The Government is failing in its duty to monitor the impact of UK activities on biodiversity. The current policy within Natural England to only use open severely hampers access to the biodiversity data they need to adequately assess the status of key species in the UK. Furthermore, Natural England is severely underfunded and is unable to fully carry out their statutory duties with regard to monitoring National Nature Reserves and SSSIs. These two issues in combination mean that the government does not have a clear picture of England’s biodiversity and, therefore, are unable to monitor the effects of the UK’s activities nor adequately devise measures to improve it. The country nature conservation bodies in the devolved nations do fare better, however, none of them are resourced to the levels required to properly monitor and improve the environment.

The Government has performed poorly against the Aichi Biodiversity Targets. The latest report in 2019[1] showed that the UK was going to miss 14 of the 20 targets. There has been insufficient progress on all of the targets that relate to the halt in the decline, restoration and safeguarding of biodiversity on land and in the sea. Even some targets that are shown as on track could be disputed, such as target 19 which requires the improvement, sharing and application of the science base and technologies relating to biodiversity. The UK government, in particular in England, has reduced funding for the vital work that is undertaken to record and curate species occurrence data and the digital infrastructure required to enable the wide sharing and use of these data. The biodiversity data sector, which provides the data to underpin so much government policy is severely underfunded, which is already having a severe impact on the collection, curation and availability of biodiversity data.

In order to tackle biodiversity loss, it is essential that there is a sound evidence base to inform policy and decision making. High quality biodiversity data is crucial to the delivery of the 25 Year Environment Plan and the statutory reporting, design and monitoring of measures required to halt and reverse biodiversity loss. Data are essential for Biodiversity Net Gain, Natural Capital Accounting, Nature Recovery Networks, Local Nature Recovery Strategies and the Environmental Land Management Scheme. In short, it will be impossible to tackle biodiversity loss without comprehensive, high quality data. Therefore, if Government is serious about its commitment to tackling the climate emergency and biodiversity crisis, it has to provide support for gathering, managing and sharing the data that provides the essential evidence base on which its policies will be based and measured.

Evaluating measures to conserve and enhance biodiversity:

In order to play a part in maintaining and improving biodiversity the ELM scheme needs to be evidence based. It should be devised and delivered at the landscape scale and make a significant contribution to the Nature Recovery Network. It should also have well defined and measurable outcomes to ensure it is indeed improving biodiversity. It is hard to see what improvements to biodiversity will be made under Tier 1 of the ELM scheme as many of the activities in this tier could be interpreted as business as usual for farmers. Tiers 2 and 3 have real potential to deliver improvements and encouraging collaboration between farmers and land managers is welcomed. Tier 2 could be improved by placing more emphasis on joining up habitats and incorporating land under the ELM scheme into Nature Recovery Networks. One alternative land use that does not appear to have been considered is rewilding. Incentivising this under the ELM scheme could promote the implementation of multiple interventions in one area at the same time.

Making biodiversity net gain a condition of planning permission in England is a good step forward. However, there are some flaws with this approach. For example, only requiring an enhancement to be maintained for 30 years after completion of the works could result in newly created habitats being destroyed before net gain has been realised. Nationally Significant Infrastructure Projects and other large scale infrastructure projects should not be excluded from the requirement to deliver biodiversity net gain as they could impact on significant tranches of land.

The biodiversity value and biodiversity metric which are to be used in assessing whether biodiversity net gain has been realised is flawed. The value and metric rely solely on the assessment of habitat and do not have any regard for the species found within these habitats. Under these assessments it would be perfectly possible for the application of biodiversity net gain to result in the provision of habitats that are less biodiverse. Biodiversity by definition includes the variety of species within a habitat. To have a biodiversity metric which does not take account of this seems flawed.

Biodiversity net gain and Nature Recovery Networks go some way to address the issues surrounding how to value nature, but they do not go far enough. As mentioned above biodiversity net gain does not take account of species and, therefore, does not address the issues involved in assessing their individual or ecosystem value. The biodiversity net gain calculator also has limitations when used for smaller sites.

Biodiversity net gain can complement existing frameworks, e.g. the Mitigation Hierarchy, but it is important that net gain is additional to the hierarchy and only comes into play once the impacts of development have been avoided, mitigated and compensated.

It is not clear how biodiversity net gain and district licensing for protected species work together. It is essential that these are complementary and demonstrable net gain is delivered for protected species.

It is essential that the planning of Nature Recovery Networks is based on robust evidence. Data are needed to determine the best locations for local nature recovery networks to identify where good, biodiverse, habitats already exist and where they need to be created to ensure habitats can be joined together. Detailed Nature Recovery Network maps and plans need to be produced at the local, regional and national levels. The maps should provide a spatial plan that identifies the best options for delivering benefits for nature. The maps and knowledge of the network would then need to be used for local planning decisions and decisions on biodiversity net gain offsetting.

The Nature Recovery Network should be funded, at least in part, by government, potentially through tax hypothecation. There should be contributions from agri-environment schemes and developers under the polluter pays principle. Funding of the networks should not be left to not-for-profit organisations or conservation NGOs, as so much of the measures to conserve and restore the environment seem to be.

Delivery of Nature Recovery Network should be done in partnership, between government (local and national), developers, regulators and land managers of all kinds e.g. conservation organisations, farmers and foresters.

We aren’t able to comment on the effectiveness of specific policies, however, as stated in the State of Nature Report 2019[2], while there have been some notable individual conservation successes, conservation efforts in the UK “have been insufficient as yet to stem or reverse the net loss of nature.” This would suggest that overall government policies have been ineffective for the conservation and enhancement of existing natural habitats. As an example, public funding for tree planting and woodland creation, including the Woodland Grant Scheme, have been made available in various guises for decades. However, the level of tree planting in the UK over the same time period has been in decline[3].

Co-ordination of UK environmental policy:

Biodiversity, climate change and sustainable development are interlinked and a policy to address one cannot be developed in isolation from the others. A healthy planet, which is a biodiverse planet, is at the heart of human health and well-being. Therefore, a regard for and requirement to make sure any decisions do not have a detrimental effect on biodiversity should be included in all government policies. In particular, the Environment Bill, Agriculture Bill and planning policies should be complementary and closely aligned.

A healthy, resilient natural world is a biodiverse one. Without biodiversity it will not be possible to achieve the air, soil and water quality objectives in the 25 Year Environment Plan. Increasing biodiversity through green infrastructure plays a part in trapping pollution, absorbing gases and excess water and healthy trees can remove significant levels of air pollution in cities. High biodiversity is essential for soil health and to increase its resilience to environmental challenges, not to mention its importance for carbon and nitrogen cycles. Studies have also found that biodiversity improves water quality, for example the amount of algae species in a habitat affects the speed at which nitrate is removed from water[4].

It is difficult to determine how well the UK is addressing biodiversity loss in its OTs as there are no comprehensive data on the majority of species that are believed to inhabit these areas. It is estimated there only a third of the species have been recorded. Of the nearly 6,000 species in the OTs that have been assessed for the global IUCN Red List, 10% are classed as threatened and therefore at risk of global extinction[5].

The outcomes from COP 15 need to be truly transformative. Actions have to result in biodiversity being ‘mainstreamed’ and at the core of all decision making, for businesses, governments and the general public. Urgent action is needed to not just halt but reverse the decline in biodiversity. Biodiversity is fundamental to human health and well-being, and is critical to providing food, energy and medications as well as key to tackling the climate emergency and dealing with pollution. There need to be incentives for policies and activities that integrate nature and nature based solutions and disincentives for activities that are detrimental to biodiversity. Any actions need to have clear, measurable indicators of success and must be designed and monitored using robust, reliable data. Finally, whatever the outcomes and protections that are agreed upon, there needs to be a real commitment from all involved to actively implement the measures needed to bring about benefits for biodiversity at national and international levels. The failures in achieving the Aichi Targets cannot be repeated.

Pairing nature-based solutions to climate change with biodiversity:

As biodiversity and the solutions to climate change are inextricably linked, it is hard to think that any nature based solutions would not be beneficial for both climate and biodiversity goals. Restoration of peatland, species rich grassland, woodlands and wetlands would all provide benefits for both biodiversity and climate change. Similarly, protection of marine animal populations, saltmarshes and seagrass meadows could achieve positive outcomes for both issues. Not only will restoring these habitats and increasing biodiversity assist with carbon capture, they will also provide benefits in terms of healthier, more resilient environments, flood prevention, coastal defences and increases in human health and well-being.

The obvious clear indicators of progress of nature based solutions would include a halt or reversal of biodiversity loss, progress towards net zero and a reduction in climate change. However, none of these will be evident quickly. It is essential that nature based solutions are given the time to have an impact and that robust data is collected before, during and after implementation of any interventions so that progress can be properly measured and monitored. We need to start implementing nature based solutions immediately, time is of the essence if we are going to have any meaningful impact on reversing biodiversity loss.

The Nature Based Solutions Initiative produced a brief on the cost effectiveness of nature based solutions where they judged the magnitude of event against which the intervention can be effective and the spatial scale over which it is effective against affordability, in both the long and short term. It was also scored depending on the co-benefits it brought[6]. The Waves Partnership have also produced a review and recommendations of how the ecosystem services of mangroves and coral reefs can be measured and valued[7]. Both of these publications would be useful in determining how the success of nature based solutions could be measured.

Government initiatives will have to play a big part in funding nature based solutions. There should be incentives for implementing NBS and disincentives for practices that are detrimental to biodiversity and ecosystems. The benefits to the private sector in contributing to funding of nature based solutions, e.g. lowering operational costs, increasing customer engagement and unlocking new revenue streams need to be clearly explained. This could be further enhanced through the provision of financial support, including bank financing, for organisations to include conservation projects in their projects. Co-ordinated focus should also be placed on effective implementation, oversight and enforcement of regulatory developments that ensure meaningful investment by the private sector in meeting the “E” of ESG (Environmental, Social and Governance) requirements. 



September 2020





[4] Cardinale B. (2011) Biodiversity improves water quality through niche partitioning. Nature 472, 86-89