Tesco believes that any move towards a truly sustainable food sector requires a holistic approach, with government, industry and civil society working together to overcome gaps that currently exist between policies and standards of practice across different countries, sectors, and parts of the value chain.
We see the following as particularly important for the improvement of biodiversity as part of a sustainable food production system:
Biodiversity is a key element of Tesco’s sustainable agriculture agenda and a key area of focus within our supply chain. We welcome the opportunity to respond to this important inquiry and the continued work of the Environmental Audit Committee.
Tesco have previously provided feedback as part of the Government’s Health and Harmony consultation in 2018 and the Environmental Land Management (ELM) consultation earlier this year.
The state of biodiversity:
How effectively is the Government monitoring the impact of UK activities on biodiversity, at home and abroad?
As a large UK retailer we are legally required to report Scope 1 and 2 carbon emissions data and limited Scope 3 emissions data in our annual reporting cycle, in accordance with the UK GHG Protocol. However, this methodology does not account for the majority of our emissions, which come from our agricultural supply chains (circa 60% of Tesco’s ‘cradle to Tesco’ emissions), both domestic and international. Recognising this, we have carried out a carbon footprint exercise which enabled us to set our carbon reduction strategy, focusing on our key hotspots, including agriculture. We have, however, found it challenging to engage our supply chain on carbon reporting and reduction, as the majority of our suppliers do not have the same carbon reporting requirements from government that Tesco have.
There is no such requirement for Tesco to report its progress on biodiversity from government. It is also worth noting that there is no clearly defined and adopted way to measure biodiversity – although NGOs and investors have been asking for more information on businesses progress in this area recently.
In 2018, we announced a new partnership with WWF, with the ambition of making it easier for customers to access an affordable, healthy and sustainable diet. Through the partnership, we aim to halve the environmental impact of the average UK shopping basket. As part of the partnership, Tesco is working with many expert stakeholders to investigate, and trial potential metrics and strategies to restore nature in food production. This is at the same time as maintaining our wider focus on nature restoration. Our sustainable agriculture agenda is described below in more detail.
How has the Government performed against the Aichi Biodiversity Targets and what further progress is needed?
The Aichi Biodiversity Targets established ambitious and necessary steps to be taken to halt biodiversity loss and protect and enhance ecosystems. Whilst action has been taken by the UK, a number of key targets have progressed at an insufficient rate. Acceleration across all target areas is needed to achieve the strategic goals. It is also important to recognise the imperative for a joined-up approach across the four nations of the UK. At present, progress against the Biodiversity Targets is highly varied across the four nations. As a company with UK-wide operations, a harmonised approach to making progress on our biodiversity commitments is vital.
In order to accelerate progress, application of the targets and their UK interpretations would benefit from having clear and consistent metrics in place, that can be used as a way to measure improvement of biodiversity over time. As a company, we recognise that identifying consistent and robust biodiversity metrics to be applied at scale is complex. As such, we are looking to trial and assess biodiversity metrics appropriate for farm-level action and intervention.
In terms of specific targets, Target 4 focuses on sustainable production and consumption. As the UK’s largest retailer, we are very focused on this area, and are working in partnership with WWF to address systemic issues of unsustainable production and consumption within the UK food system. Our CEO Dave Lewis highlighted this in his recent op-ed entitled ‘The UK’s food strategy cannot be left to the market’ when he stated that “The UK produces only half its food; we must ask tough questions about efficient land use. That means eating less meat and dairy, which uses 70% of agricultural land and emits 14.5% of greenhouse gases globally”. Tesco’s work and partnership with WWF alone will not be able to achieve the required goals, which led him to conclude that “We cannot do this without incentives for sustainable farming and a strategy to help livestock farmers diversify. Measures are needed to help people adopt more nutritious diets, from fruit and veg subsidies, to a focus on nutrition and diet in education”. We recognise the need to reduce meat and dairy consumption within the UK, and would support action taken by government, in consultation with industry and civil society, to establish clearer consumption targets for meat, dairy and plant-proteins.
There has been some progress made towards Target 5 (halving the rate of loss of natural habitats including forests) as part of the government-backed Global Resources Initiative (GRI). The Initiative convened a taskforce of leaders from business (including Tesco), finance and civil society to establish a set of recommendations for addressing land, natural resources and ecosystems issues occurring through the global commodity supply chain footprints of UK companies. Tesco stands behind the recommendations put forward by the GRI and we hope to see a due diligence requirement in place through the Environment Bill that mandates food companies, including food service, to undertake necessary due diligence to ensure deforestation-free supply chains.
Tesco is keen to share best practice, learn from others and work with government and society on these big issues.
Where should the four nations prioritise resources to tackle biodiversity loss?
Farmland in the UK covers 72% of land (not including woodland and forest). Due to the reliance on pollinators, soil health and water availability for food production, in addition to biodiversity, our sustainable agriculture strategy reflects these areas explicitly. We would welcome a strengthened focus on these areas by UK governments. Tesco is also focusing on carbon reduction and we are investigating carbon sequestration options on farmland which has co-benefits for biodiversity. Looking forward, it is imperative that any UK biodiversity strategy or issue prioritisation recognises the interconnectivity of issues (including dependencies) and takes an approach which is harmonised across the devolved nations.
At Tesco, we regularly receive feedback and provide advice to our farmers, and welcome the opportunity to work with broader stakeholders to ensure appropriate steps are taken to protect biodiversity, including providing appropriate advice to stakeholders. An example of the need for a joined up approach is specific feedback from our supply chain and partners in the Wye and Usk catchments on the siting of poultry and dairy units. Some of these farming units have been sited too close to the river catchment increasing the occurrence of diffuse pollution from slurry and soil erosion into the rivers. These units have all been built with approved planning permission, so there may be the need for some work with local planning authorities to raise their awareness of biodiversity impacts. There is also education and awareness work required for the farming operations and food and drink companies that source from those areas. Tesco is co-funding an environmental farm adviser to visit farmers in that catchment, providing independent advice to support farmers to improve farming practices for the environment, as well as two others in the UK and two internationally.
Environmental advice for farmers is currently fragmented across the UK, but it is recognised as a key change enabler which helps deliver sustainable agricultural practices, maintaining and protecting ecosystems and biodiversity. As such, Tesco is exploring the development of a national environmental advice database, with WWF and other stakeholders, that is free and easy for farmers to access, enabling them to find local experts for on-farm advice. Ideally this database would be centrally supported and continuously improved and updated. We would therefore welcome UK Government engagement and support for such a nationwide initiative.
Evaluating measures to conserve and enhance biodiversity:
How should the Environmental Land Management (ELM) scheme maintain and improve biodiversity? What role might alternative land use play in delivering improvements to biodiversity under the ELM scheme?
The UK has a great opportunity with the development of the ELM scheme to make real progress toward the 25 Year Environment Plan (25YEP) and Aichi Goals. The ELM scheme could be most effective by ensuring it rewards improvement of biodiversity beyond that which is already required as part of environmental regulation. Incentivising farms and landowners to take a holistic approach to environmental management and continuous improvement could ensure that there is no unintended negative impact on the environment. Farm advice can have a role in supporting this, as well as landscape-scale partnerships. These should enable greater improvements that go beyond just farm-level.
How effective are the new measures to enhance biodiversity within the Environment Bill, particularly biodiversity net gain and Nature Recovery Networks? Do these measures complement existing regulatory frameworks and address issues surrounding how to value nature?
These measures could be beneficial if they work as intended. It will be important to understand how these two measures can most effectively work together to pursue the landscape approach, for example, by using new developments in biodiversity net gain to support and link to Nature Recovery Networks. Recognising the importance of landscape-level approaches, Tesco and WWF are working together to link farm-level activities within our supply chains through the development of wider regional or landscape level interventions.
How should Nature Recovery Networks be planned, funded and delivered?
We would recommend consulting with relevant experts to determine how Nature Recovery Networks could be best developed and delivered. Linking up public and private sector funding could be an excellent opportunity to fund investment in Nature Recovery Networks development. Landscape Enterprise Networks (LENS) are a good example of establishing funding for a network, by creating business value from healthy landscapes. This is an area that Tesco is exploring and it is likely that having government support for these initiatives, through ELMs or other similar avenues, would help encourage more private sector stakeholders to collaborate.
How effective are other policies for conservation and enhancement of existing natural habitats, such as the Woodland Grant Schemes?
While Tesco is not familiar with the efficacy of these schemes, we are supportive of policies and schemes that deliver improvement to biodiversity.
Co-ordination of UK environmental policy:
How can policy be better integrated to address biodiversity, climate change and sustainable development?
The consideration of climate change, biodiversity and sustainable development in the policy-making process has improved over the last decade, as awareness of the issues and the benefits of having a healthy planet are realised. We support the ambition of the National Food Strategy and continue to highlight the importance of ensuring that policy is joined up across departments, to deliver food that is healthy, sustainable and affordable for all.
How can biodiversity and ecosystems help achieve the air, soil and water quality objectives in the 25 Year Environment Plan (25YEP)?
By including biodiversity requirements within the ELM scheme, this should help to ensure that the co-benefits on air, soil and water quality are realised. However, it will be necessary to understand the level of improvement required at both the farm and landscape-level to achieve the 25 YEP targets. This will be key to enabling the agriculture and food and drink sectors to work towards a common goal.
How well is the UK addressing biodiversity loss in its Overseas Territories and in international development partnerships with other countries?
As highlighted earlier, Tesco has been working as part of the Global Resources Initiative (GRI) to support the recommendation for government to mandate due diligence on forest commodities for food and drink companies. This would be a good first step, and one which can be built on, in starting to address biodiversity impact and the drive for greater transparency across sourcing locations.
There is also a window of opportunity for the UK, as it negotiates new trade deals, to embed sustainability and high environmental standards at the heart of every deal. This would help accelerate the transition towards reliable, resilient, and sustainable supply chains that benefit both people and the planet.
What outcomes and protections should the UK Government be pushing for at the forthcoming UN negotiations on the post-2020 global biodiversity framework at the Convention on Biological Diversity COP 15?
Collaborative action from governments, food and drink companies and local communities to understand environmental impacts and establish environmental governance and stewardship in sourcing locations, would help to improve the transparency of the sustainability of food production.
Economics and biodiversity:
What are the possible approaches to balancing economic growth and conservation of nature and its contributions? Is there evidence these approaches work and can be implemented?
As mentioned earlier, the LENs approach could be a way of creating natural capital that the private sector and other stakeholders can invest in and benefit from.
Investment in nature and biodiversity is a vital part of the UK’s recovery from the COVID 19 pandemic, including investing in rural employment and adapting to adverse climate effects and impacts. Research conducted by Vivid Economics shows that investment in parks will reduce health costs, cut air pollution and improve many other aspects of urban life, including wellbeing.
What does the UK Government need to do to maximise human prosperity – in terms of health, economic, and social wellbeing—within the ecological and resource constraints of a finite planet? What alternative models and measures of economic welfare can feasibly help achieve this?
Ensuring that the Government’s commitment to net zero reflects the need for a just transition is important.
Pairing nature-based solutions to climate change with biodiversity:
Which nature-based solutions are most effective in achieving both climate and biodiversity goals?
Some nature-based solutions that are effective include: restoring and protecting forests; agroforestry; soils sequestration; restoring wetlands and peatlands; nature into cities via green urban planning; coastal habitat restoration; regenerative agriculture.
Tesco welcomes and encourages the planting of trees within our agricultural supply base as one (of many) ways of tacking climate change through sequestration. Tree planting offers potential for sectors to support scale-up into the future as a way of achieving Net Zero targets, so this nature-based solution will need to be regulated or some principle to be established. This will ensure the trees are located appropriately, reduce negative impacts on biodiversity and ensure no ‘double-counting’ has occurred as part of carbon accounting.
What would constitute clear indicators of progress and cost-effectiveness of nature-based solutions and how should trade-offs and co-benefits associated with nature-based solutions, biodiversity and socioeconomic outcomes be considered?
From an agricultural perspective, progress could be illustrated by lower inputs resulting in increased yields. Embedding payments for credible ecosystem services into the true cost of doing business would also help to progress biodiversity improvements.
How can funding be mobilised to support effective nature-based solutions to climate change? How can the private sector be encouraged to contribute to funding?
As mentioned earlier, the LENs approach could be a way of creating natural capital that both private sector and other stakeholders can invest in and benefit from.
 Tesco supports Greenpeace aim to end Amazon deforestation and calls for deforestation-free food in the UK
 Current Agricultural land use in the UK, Savills, Jan 2019, https://www.savills.co.uk/research_articles/229130/274017-0
 Algal Bloom, Wye and Usk Foundation, 2020, https://www.wyeuskfoundation.org/algae
 WWF & Vivid Economics report on net-zero transition benefits for economic recovery