Evidence by the National Trust to the Environmental Audit Committee


With our staff, members, volunteers and supporters, the National Trust is the biggest conservation charity in Europe. We protect and care for places so people and nature can thrive. Many millions share the belief that nature, beauty and history are for everyone. So we look after the nation’s coastline, historic sites, countryside and green spaces, ensuring everyone benefits. For everyone, for ever.





We are answering the following questions.


1. How effectively is the Government monitoring the impact of UK activities on biodiversity, at home and abroad?



Existing environmental monitoring across the UK is ineffective. Evidence compiled by Greenpeace shows that fewer than half of SSSIs in England have been monitored in the last six years. The UK’s 2019 report under Article 17 of the Habitats Directive mentions a number of habitat and species groups where there is not sufficient data to allow proper reporting (http://data.jncc.gov.uk/data/6420776d-2a25-4575-8b6f-1922a6a13806/Article17-UK-Approach-2019-A.pdf). Without proper or adequate monitoring, it is impossible to determine whether government policies or interventions have been effective or not.


The Government has committed to introducing new environmental monitoring and evaluation in England through the 25 Year Environment Plan indicator framework. At present, many of the indicators in the framework cannot be populated with data as it does not exist to a high enough quality or quantity to use. On-going investment in appropriate monitoring and supporting systems will provide better and more up to date data that will be crucial to ensure the Government can achieve many of its ambitions. For example, without robust (site-specific) baseline data it will be impossible to safely roll out Biodiversity Gain or the major changes proposed to the planning system. Strong environmental monitoring will help to inform the public about whether the Government is on track to meet existing and new national and international targets, including under the CBD and outcomes of public funded support in the new agricultural system.


A more coherent and coordinated programme of biodiversity monitoring across the UK is required to win efficiencies and develop a more robust evidence base on our natural capital. Greater support and coordination to key national recording schemes and societies and relevant environmental NGOs can pay dividends in developing this evidence base, for example the Priority Species Indicator was developed by members of the State of Nature partnership and was then incorporated into the UK Biodiversity Indicators and used to assess the UK’s progress towards the Aichi targets. This is only possible due to the significant effort and skills of the thousands of voluntary and professional surveyors who contribute towards these datasets. Greater improvements could be made to utilise other sources of data, such as those arising from planning although continuing reductions in local authority expertise and capacity are currently limiting. Current government proposals put significant onus on local authorities in monitoring the state of the natural environment, including rolling out Biodiversity Gain and more resource will need to be provided for them to discharge these responsibilities adequately.


The efficient management of biological data is difficult, with different types of data systems, collected by different bodies (e.g. National Biodiversity Network including national recording schemes and societies, Local Environmental Record Centres) resulting in inefficiencies that limits the use of the available data that could be utilised in monitoring and developing a stronger evidence base on our natural capital. The Government should recommend and implement a preferred approach to data management playing to the complementary strengths of the relevant actors.


There are many species groups that are not recorded as effectively, and red list assessments need to be conducted more frequently in order to update lists of species in decline and at risk of extinction.


The JNCC’s report, on behalf of the Government, on the UK’s progress on the CBD targets states that “There has been a short-term fall in Government funding for biodiversity in the UK, although as biodiversity has increasingly been integrated into other funding streams such as green growth, the data has become increasingly difficult to assess.” As biodiversity funding becomes more generic and part of wider funding streams, monitoring the UK’s contribution to nature’s recovery becomes more difficult.


2. How should the Environmental Land Management Scheme maintain and improve biodiversity? What role might alternative land use play in delivering improvements to biodiversity under the ELM scheme?


Sustainable farming and land management has the potential to address growing challenges like the need for flood management and to tackle carbon emissions, through adoption of natural solutions, for instance tree establishment or restoring peat bogs. These types of approaches deliver multiple benefits because they also positively impact nature, with the restoration and creation of rare and threatened habitats important for reversing biodiversity decline. The public money for public goods (PMFPG) model at the heart of the new ELM system will allow the Government to fund farmers to implement precisely these types of solutions at a scale sufficient to deliver real benefits to people and nature.


Because of its importance in delivering against the environmental goals of the 25 Year Plan, more explicit linkages need to be made between ELM and the Environment Bill, not least in terms of targets and Environmental Improvement Plans helping to prioritise support where it is most needed and making it clear how progress is to be measured. Synergies should also be maximised, and objectives aligned (whilst “double counting” avoided), between ELM and other policy drivers and funding mechanisms such as Nature Recovery Network, Biodiversity Net Gain and the Nature Recovery and Nature for Climate Funds.


Since ELM will also need to be integrated with other mechanisms proposed under the 25 Year Environment Plan, the relationship with such initiatives and benefits to a farm business should also be made clear. For example, the impact of public funding could be enhanced (e.g. complementary private finance) or more lasting funding secured (e.g. conservation covenants) through ‘stacking’ of deliverables or outcomes for different types of payment mechanism.


Overall, there is a clear and urgent need to develop innovative farming systems that aim to maintain or increase productivity and resilience to future environmental perturbations, while reducing the environmental and ecological footprint of agriculture. This will require a mixture of strategies that integrate biodiversity with productive farming by enhancing the beneficial ‘services’ provided by biodiversity, including pollination and pest control, efficient management of soil, protection of water resources and carbon sequestration.


This greater focus on nature-based solutions necessitates a shift towards more circular agro-ecosystems that reduce dependency on external inputs and promote wider integration of wildlife habitats at multiple scales through development of space-efficient, multi-functional landscapes. Our work with farmers as part of the ‘Whole Farm Plan’ test and trial project in Shropshire has shown that it is important to help farmers understand the ‘sweet-spot’ of a farm’s deliverable natural capital whilst balancing a farming system that supports and enriches its delivery. A farm can then adapt and develop in conjunction with its natural capital (e.g. beneficial predators, shelter belts, increased organic matter) dispelling the misconception that farms have to remain static.


Tier 1, as currently proposed, includes actions that most farmers could take across their farmed and forested land which is to be welcomed, but several are what we would view as ‘good farming practice’ (e.g. contour ploughing, soil protection measures) and a ‘compliance requirement’ (e.g. nutrient management) affording a private benefit to the farm business. We are concerned that, should such measures remain in Tier 1 as currently proposed, there would be a risk that significant levels of funding with only the ambition to increase farmer participation would not deliver value for money and put at risk what can be achieved through Tiers 2 and 3 with a limited budget.


Encouraging a shift to a whole-systems approach should therefore be the clear objective of Tier 1. This should focus on measures to green the farm business on a whole farm basis. Some models already exist, such as organic, agroecological and regenerative agriculture, and ELM should learn from and build on these. This will not only help give farmers a more certain and secure future knowing they are doing everything to conserve and enhance the natural asset base of their farm (including biodiversity) but can help open-up new opportunities from diversifying their farm business to engaging in new markets that attract complementary private investment.


Tier 2 should aim to deliver more locally targeted environmental outcomes, based on new spatial targeting and local planning systems, as well as a collaborative and joined-up approach. There is significant scope for this tier to be a target and vehicle for private funding such as from Net Gain, helping to re-allocate money within the area from where it was generated. This could enhance connectivity between public and private goals, facilitate economies of scale and reduce the risks of double funding. Tier 2 could therefore play a critical role in delivering more meaningful outcomes in the right place, such as on biodiversity, whilst acting as the pinnacle of most farm businesses within ELM. We therefore support the initial focus being taken to this tier as the achievable ‘powerhouse’ of ELM, but it should be recognised that a farmer’s journey may not necessarily end there, should they have increased ambitions for ecosystem services delivery. This might start with several farmers working together under Tier 2 in way that would deliver Tier 3 ambitions for landscape-scale change.


Tier 3 should involve landscape-scale, land-use change projects based on negotiated agreements and have a focus on national issues of both nature recovery and net zero. This should include forest and woodland creation, restoration and improvement, peatland restoration, and the creation or restoration of habitats such as wetlands and salt marsh. These examples of nature based land use change projects would make a substantial contribution towards the UK’s net zero target by creating and restoring carbon-rich habitat, while delivering strongly for biodiversity, water quality and flood mitigation. They could also be critical in helping deliver the Nature Recovery Network (as set out in the 25 Year Environment Plan) as well as being designed to promote opportunities for public engagement and access.


3. Where should the four nations prioritise resources to tackle biodiversity loss?


Working within the current devolved frameworks the four governments of the UK should work together to agree upon coherent and appropriately aligned approaches to the recovery of biodiversity, in order to sustain and enhance the ecological integrity of the UK and taking into account the shared species, habitats and ecosystems that occur across the four nations.


Environmental Governance


There is a need for the environmental governance gap that is faced after Brexit to be closed and as part of the Government’s commitment to a green Brexit and ‘no regression’. The level of environmental protection, monitoring and governance in the nations of the UK must be brought onto the same level as, to date, disparities have existed in the level of priority given to the environment across the four nations.


Investment in nature-based solutions


All of the UK nations should work to develop solutions that restore our natural capital and help both nature and the climate. For example the restoration of peatlands and species rich floodplain meadows can mitigate locked in impacts of climate change such as reduced flood risk, help lock away carbon and benefit biodiversity as well as delivering better public services such as improved water quality.


Development of a Nature Recovery Network


Ecological networks should be developed across the UK (including the Nature Recovery Network for England) which would map corridors and areas of habitat that are important to wildlife and plants as well as the areas that need to be protected and restored. By improving the condition of extant sites and increasing their size we can help re-connect nature rich landscapes, develop ecological networks more resilient to environmental pressures and encourage nature to thrive against the pressures of climate change, agriculture and development. The establishment of a NRN should be evidenced based and resources targeted to optimise nature’s recovery for the benefits this offers. Ensuring that this network is reflected in law would also ensure that nature is prioritised and impacts from land use change and intensive agriculture in particular avoided.


Future farming policy


Leaving the EU has presented a once in a generation opportunity to set agriculture on a sustainable footing for the foreseeable future across the whole UK. We believe that the environment should be placed at the heart of our future farming policy. Positive environmental management will help build the long-term resilience of the sector, for example, moves to increase soil health will better equip our farming systems to safeguard themselves against the negative impacts of climate change and disease, whilst positive environmental land management in upland areas will safeguard against fire and erosion, and at the same time benefit lowland systems in reducing flood risk. We are supportive of the need for new agricultural schemes which take a “public money for public goods” approach and would support farmers in Northern Ireland to deliver for the environment. 


3. 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?


The Environment Bill (which primarily covers England) is a crucial opportunity to establish a comprehensive and effective system of environmental governance. However, we are concerned that in its current form the Bill will not do so, and thereby will fail to protect and restore biodiversity and other elements of the environment. The new Office for Environmental Protection has neither the independence of funding nor of appointment of its senior staff that are required to ensure it is a truly independent body. The OEP’s funding will come from the Secretary of State. In addition, the environmental principles are to be included in a policy statement, rather than in the Bill itself, weakening their legal effect.


A strong system of targets for biodiversity, put in place by the Bill, would be a powerful tool to drive action, and we would encourage the Government to use the Bill to introduce targets on species abundance, species distribution and on the risk of extinction. Environmental Improvement Plans should contain clear measures that will deliver the target set by the Bill.


We believe that Biodiversity Gain could be beneficial, but that certain safeguards will be required in order to maximise the benefits, and avoid any harm, to biodiversity. However, rigorous application of the existing mitigation hierarchy should be demonstrably exhausted before considering Biodiversity Gain.

An iterative approach to introducing Biodiversity Gain should be adopted so that initial lessons can be learnt and fully evaluated in order to ensure the approach does deliver increases in, and improvements for, biodiversity. Biodiversity Gain will now form part of a much wider set of planning reforms (for England) that the Government is consulting on and risks undermining government ambitions set out in the 25 Year Plan. These changes to the planning system should strengthen protections for existing important areas for biodiversity as well as allowing the expansion of natural green spaces and protected areas as part of the delivery of the Nature Recovery Network and Local Nature Recovery Strategies. Biodiversity Gain will prioritise the delivery of habitat on or near to the development site. This will deliver some improvement in biodiversity, but may miss the core areas of the country with the greatest potential for biodiversity, such as protected landscapes that are currently in a poor condition. As such, Biodiversity Gain alone will never provide a strategic, silver bullet solution for restoring England’s biodiversity, but can play an important contributing role.


Biodiversity Gain should facilitate development that is green and nature friendly, through the inclusion of green spaces within developments, as well as the creation of new green spaces through any credit system. While mechanisms exist today to facilitate the incorporation of green or blue infrastructure, this is rarely done and these barriers need to be tackled in order to secure the opportunities provided by green infrastructure schemes. Development standards, including those developed for the new planning system, should be used to raise the bar, for instances through measures like Sustainable Drainage Systems.


The national Nature Recovery Network, and its ambition to significantly increase space for nature, is very welcome. Much biodiversity and many habitats are spatially specific, and therefore a national map and the Local Nature Recovery Strategies will play an important role in helping to identify where the best interventions can be made to protect and restore biodiversity.


However, previous attempts to introduce networks and partnerships for nature have had mixed success. The Network must be based on reliable and up to date data and evidence. At present, much of the information about (for instance) Priority Habitats is from the 1980s, 90s and 00s. If Local Authorities will design and deliver most of the Local Nature Recovery Strategies (LNRS), they must be given sufficient resource to do so, including to employ Local Authority ecologists and have better access to ecological data and be able to work together across Local Authority boundaries to deploy data, and interventions, at the catchment and landscape scale. Changes to the planning system should allow potential areas for biodiversity and habitat (as identified by the mapping process for LNRSs) to be maximised.


We are also concerned that the Bill may be used as a vehicle to introduce changes to the planning system that have not been fully consulted on and that undermine the intention of the Bill or its ability to deliver for biodiversity. The Bill should help to deliver a halt of the loss of biodiversity and its recovery by 2030.


4. How should Nature Recovery Networks be planned, funded and delivered?


The Nature Recovery Network will be mapped at a national scale, with Local Nature Recovery Strategies covering the whole of England identifying existing biodiversity and habitats and opportunities too. We welcome the inclusion within the Bill of the possibility for LNRSs to span county council boundaries so as an LNRS could (theoretically) cover a National Park or AONB area. We believe that this may, at times, make more sense from an ecological point of view and that landscape or catchment-scale planning and delivery might result in greater biodiversity benefits. We are concerned that the Local Authority scale may, in some cases, be too small to deliver sustainable and coherent biodiversity benefits if it results in piecemeal areas of habitat, and that many Local Authorities lack the capacity or expertise to design and deliver LNRSs and long-term management. We strongly welcome the 25 Nature Recovery Areas (in addition to LNRSs) that will be at the landscape or catchment scale and the ability for some LNRSs to be spread across county council boundaries, allowing them to cover National Park areas.


The Nature Recovery Network should help to guide decisions in any changes to the planning system. The new proposed categorisation/zoning of land should enable areas of existing importance for biodiversity to be actively conserved, and equally, areas that have potential to be restored for the economic and public benefit this affords, to be adequately protected from development and unsustainable land management. The categorisation of land should protect existing protected sites but should also allow the area of land for nature to expand, which will be essential in delivering the recovery of biodiversity.


The Nature Recovery Network and LNRSs will require greater government investment in Local Authorities, who are seen as the principle authorities that will design and deliver plans. At present many do not have sufficient ecological expertise or capacity nor adequate influence over land management. Investment and on-the-ground action to protect and restore biodiversity will need to come from across Government, environmental organisations and land managers, and from private funding.


Delivery of Local Nature Recovery Strategies will need to be funded by a blend of public and private sector finance. They will need to rely in part upon the new Environmental Land Management system, and measures taken by farmers should be guided by local or regional priorities identified through the LNRS. Additionally, Biodiversity Gain will play a role in helping to deliver LNRSs and, in some cases, the use of pooled funds or credit schemes could help to deliver larger, combined interventions for nature. In addition, Government investment can help to encourage private investment, particularly if spent on initial project scoping and design work, getting projects to the shovel-ready stage, or through solutions such as green bonds where the Government can encourage citizens to invest their money to provide financial underwriting for private investment in ecological solutions.


5. How effective are other policies for conservation and enhancement of existing natural habitats, such as the Woodland Grant Schemes?


There has been some important progress in aiding the conservation and restoration of biodiversity and habitats in recent years and decades. The reintroduction of keystone species such as beavers, or persecuted species such as red kites, has been very successful. The joint efforts of Governments and environmental organisations have at times delivered significant benefits for biodiversity.


Damaging practices must be ended in order to protect habitats, before restoration can even begin. In some places government policy has entirely failed in this regard. For example, managed burning continues to damage the UK’s peatlands and we continue to use peat compost, causing destruction of peatlands at home and abroad and contributing to our environmental footprint. The voluntary approach (through targets introduced in 2010) has failed and it is time for the use of peat compost, as well as managed burning of peatlands, to be banned.


It is also important to highlight that some of the most successful interventions for biodiversity have been statutory protection for our most significant sites – including the Birds and Habitats Directives. For example, evidence shows that sites protected under these Directives are the best places for new colonising species arriving as a result of climate change, as they are m ore hospitable than the wider countryside.


Despite these policies, biodiversity continues to decline, with the 2019 State of Nature reports showing that 41% of species are declining due to climate change, intensive agriculture, fragmentation of habitat, pollution of water bodies and other drivers identified in the report. Policies must be designed that turn this decline around across the board.


The existing planning system and the protections it provides to designated sites and sensitive areas are somewhat effective although more consistent adoption of good practice (e.g. utilising existing provision within the EIA Regulations to tackle air pollution on protected sites) by key regulators would secure greater wins. This must not be lost in any major overhaul of the system, and protections should be strengthened rather than replaced to ensure no regression. There are examples where even some of the most strongly protected sites have come under threat of development (for example a SSSI home to 1% of England’s breeding population of nightingales) that was threatened by a housing development. If the Government is to introduce a system of land categories in England based on existing protected areas, Local Wildlife Sites and green spaces, then existing protections for these areas need to be enforced and strengthened. It is important to recognise that many Local Wildlife Sites, particularly those in private ownership, may not be in a good condition or may not have been recently monitored. Therefore, if the Government is to prioritise their protection through the planning system, then enough resource must be available for their management and monitoring and for advice to those who own and manage them.


One of the main problems with conservation policies is their inability to cater for, and give appropriate prescriptions for, specialist species or groups of species. The Woodland Grant Scheme is a good example, since it actually fails to prescribe any measures relating to biodiversity. If conservation policies and interventions are to succeed, then advice to land managers (woodland owners, farmers) is an essential element and must include specific actions that can be taken to help biodiversity that depends on particularly habitats or ecosystems.


6. How can policy be better integrated to address biodiversity, climate change and sustainable development?


Policy integration between sustainable development, biodiversity and climate change can be aided by strong political signals at the most senior levels. The UK is host of the climate change conference in 2021 and will also take part in the UN biodiversity conference that sets new goals for 2030. In addition, the UK is aiming to help achieve the UN’s 2030 Global Goals. A strong recommitment to all three of these areas from the highest political levels in the UK and the four nations would help to create the political impetus for policy development that integrates all three.


A memorandum between the two UN conventions (on biodiversity and climate change) would help to ensure that perverse outcomes are avoided (such as monoculture plantations that could help meet climate targets but harm biodiversity) and that they both help to deliver the UN 2030 Global Goals.  As Sir Bob Watson, former IPCC chair and now IPBES Chair, said joining the dots between climate, nature and land degradation is now crucial: “Governments have focused on climate change far more than they have focused on loss of biodiversity or land degradation. All three are equally important to human wellbeing." The UK’s State of Nature 2019 report and global evidence of insect decline has underlined the importance of changing farming practices to restore abundant farmland wildlife and soil life.


Sustainable development can be achieved by applying the highest design standards to new developments ensuring that housing developments and other buildings have green and blue infrastructure woven through them and built into them. A network of green and blue spaces across towns and cities can help to improve people’s quality of life, their mental and physical health, and air quality. The Government’s plans for reform of the planning system in England mention the need for developments to be beautiful and we strongly welcome this. A key element of this will be building in green space for people and nature.


Changes to the Treasury’s Green Book, including a net zero rule (which ensures that all decisions have to contribute to meeting the Paris Agreement targets) would help to ensure that spending and infrastructure decisions deliver, rather than undermine, the UK’s achievement of its carbon budgets and net zero target. In addition, key findings and recommendations from the Dasgupta Review of the economics of biodiversity should be acted upon and should also be incorporated into the Green Book, in order to ensure that benefits to biodiversity and ecosystem services (which can deliver an ROI of 19:1 (according to Sir Partha Dasgupta’s interim report)) are maximised.


Major infrastructure (including Nationally Significant Infrastructure Projects) should be part of the Biodiversity Gain system in order to ensure that major development can also deliver major benefits for nature and biodiversity.


The Office for Environmental Protection will need to be able to point to action required by a range of government departments (not just the departments for the environment or for energy) to meet biodiversity and climate change outcomes.


7. How can biodiversity and ecosystems help achieve the air, soil and water quality objectives in the 25 Year Environment Plan?


Many ecosystems and species play a crucial role in helping to purify water and air and to improve soil quality. Therefore, restoring biodiversity can help to achieve these outcomes. In turn, improving air, soil and water quality can benefit biodiversity. There is growing evidence of the ability of ecosystems and organisms to provide benefits to soil, water and air. The Office for National Statistics has found, for instance, that vegetation provided £1.3 billion of pollution removal from air in 2017. Ecosystems and biodiversity provide extremely important ecosystem services that will help to meet other areas of the 25 Year Environment Plan.


Delivering the goals and targets of the 25 Year Environment Plan will require approaches which tackle the most damaging practices and behaviours that affect air, soil and water quality. Nevertheless, it is clear that working with nature can also help reduce the impacts of pressures and help natural systems recover. Nature based solutions have a role to play across air, soil and water quality targets but it is important that such interventions are true to their word and ensures action specifically for biodiversity are included in any delivery. This is because measures that help deal with pollution rarely support the most sensitive and hence rarest species. As an example, a wetland designed and located to help with wastewater treatment will accumulate nutrients over time becoming less and less suitable for the many freshwater and wetland species that depend on clean water.


Understanding and working with the environment as a system is at the heart of ensuring these nature based solutions can work and help deliver the objectives. For example, land managers can implement actions that benefit biodiversity, soils and water. However, success is very location specific and may require advice and technical input. 



Clean and plentiful water


Achieving the objectives for water will require an integrated approach to managing our catchments and the water environment. The processes of river basin planning and the Catchment Based Approach are good foundations from Water Framework Directive implementation in England. Better integration of biodiversity and water management delivery at the catchment scale is key to ensuring we can deliver the improvements to the water environment whilst also delivering for biodiversity. By targeting areas unsuitable for intensive agriculture (low grade land, floodplains, high erosion risk areas) and incentivising habitat restoration and recreation in these areas, it will be possible to deliver significant biodiversity gains whilst removing or reducing some of the sources of diffuse agricultural pollution. Similarly, the strategic planting of hedgerows or woodland could help with disrupting runoff pathways which contribute to water pollution and flood risk. As such we believe the development of the Nature Recovery Network could also play a role in improving the status of our waterbodies. By categorising key areas, such as floodplains, within the new ELM scheme habitat creation and restoration could be encouraged where there are multiple benefits.


In integrating actions for water and biodiversity it is important to note that much of our current protections and actions for freshwaters are focused on larger water bodies whilst the smaller waters (ponds, lakes, wetlands and headwaters) are often the most important for biodiversity. As such actions that safeguard and enhance freshwater and wetland biodiversity will require a greater focus and greater protection for smaller water bodies. Given that nutrient enrichment and poor water quality are among the most significant pressures affecting freshwater biodiversity it is important that we do not rely on multi-use wetlands/ponds for biodiversity. Work by the Water Friendly Farming project  has shown that these issues can be overcome by the simple inclusion of new clean water ponds alongside nature based measures in an intensive arable landscape. 


Wetlands in general can play an important role in ‘slowing, storing and filtering’ water with downstream benefits for people and biodiversity. Centuries of drainage and ‘land improvement’ have removed many of these wetlands from our landscapes thus depriving us of important functions. Restoring these wetlands has very clear benefits as demonstrated by the wide range of successful blanket bog restoration projects. 


Improving soil health


Unlike air (Clean Air Act 1993) and water (Water Framework Directive) there are no policies that directly protect soil health. Soil has instead been partially protected under legislation relating to planning, building, and agriculture. The inclusion of soil in the 25 Year Environment Plan and ELMS is a unique opportunity to introduce cross sector targets that will improve soil health benefiting biodiversity and ecosystems.


Ecosystems and biodiversity struggle where we fail to look after the soil, with declines in above ground biodiversity and many of the water quality issues facing our rivers and lakes in part the direct result of poor soil management. Poor soil management which leads to compaction, soil erosion and nutrient runoff can in turn have direct impacts on people (flooding, increased water treatment costs) and biodiversity (loss of habitat and food).  Healthy ecosystems naturally have healthy (for that land use/type) soils as they cannot thrive or function on degraded soils, so the creation of new habitat and the improvement and protection of existing habitat will benefit local soil health.


Protecting and improving soil health will also protect, the much overlooked, soil biodiversity, which is essential in enabling soils to support healthy ecosystems and deliver ecosystem services. The biodiversity of soils is made up of a range of living organisms including micro-organisms (e.g. bacteria, fungi, protozoa and nematodes) and meso-fauna (e.g. acari and springtails), as well as the more familiar macro-fauna (e.g. earthworms and termites). Plant roots can also be considered soil organisms in view of their symbiotic relationships and interactions with other soil components. 


These diverse organisms interact with one another and with the various plants and animals in the ecosystem forming a complex web of biological activity. Soil organisms contribute a wide range of essential services to the sustainable function of all ecosystems:

These services are not only essential to the functioning of natural ecosystems but constitute an important resource for the sustainable management of agricultural systems.


8. 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?


The Dasgupta Review (mentioned above) should be used to shape the Treasury’s Green Book and also to guide decisions on the Government’s Spending Review. The Dasgupta Review should make specific recommendations, if possible, about how the Government could redistribute departmental budgets in order to maximise benefits to the environment, in particularly to biodiversity and the public benefit it provides. As far as possible, economic development should be decoupled from an environmental impact, without simply offshoring the impacts. However, in some cases an environmental impact will remain unavoidable, such as where development takes place. This is where provisions such as Biodiversity Gain play an important role in ensuring that economic growth is sustainable and results in a net increase in nature. Nonetheless, such approaches require important safeguards and certain habitats, ecosystems and places should be beyond the scope of economic development, if they are extremely rare or are irreplaceable (for example ancient woodlands).


Creating new markets in which beneficiaries pay for ecosystem services can help to internalise the benefits of nature conservation. For example, the National Trust has worked with Green Alliance to develop the concept of Natural Infrastructure Schemes – private markets in which land managers work individually or in groups to auction the environmental benefits they provide to private beneficiaries (for example to a utilities company that benefits from reduced flood risk, achieved through re-naturalising rivers further upstream).


Further evidence of how nature conservation can contribute to economic growth includes:


9. 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?


Maximising prosperity will rely upon ensuring a green recovery from the impacts of lockdown and COVID-19. Long-term recovery cannot be about short term economic growth alone. The goal should be a recovery that builds social, cultural and natural capital, drives a low carbon transition, and delivers climate resilience and mitigation alongside economic gain. Sustainable economic activity and job creation that meets the needs of the future should be the aim. 

The pandemic has not impacted everyone equally, and those living in lower quality environments, without access to nature or culture have been particularly affected. Our recovery should leave a legacy of more high quality, locally distinct places where everyone can enjoy nature-rich, green spaces on their doorstep, access to local heritage and shared cultural spaces that help bring communities together.

This means a recovery that:



  1. Environmental Improvement: every project must be compatible with the overall aspiration to improve nature and create an environmentally resilient economy.
  2. Net Zero: every project or industry that benefits from public money must be compatible with or further our net zero emissions responsibilities.
  3. Net Gain: any infrastructure delivery projects—public or private—that receive public money as part of a fiscal stimulus should be required to achieve net gain for biodiversity.

Research commissioned by the National Trust has shown that many people in the UK lack sufficient access to green spaces. This deprivation is more pronounced where more than 40% of the population is from an ethnic minority background, and where people have lower incomes. Human prosperity and wellbeing come in large part from people’s physical and mental health. The connections between access to nature and green spaces, and people’s health, are well established. However, lack of access to these spaces for many people may be harming their wellbeing and prosperity. 

A £5.5 billion commitment to an urban green infrastructure fund as part of the Government’s recovery stimulus could potentially bring an impressive £200 billion in physical health benefits through disease prevention and mental wellbeing benefits to alleviate some of the strain on local health service providers and to improve people’s quality of life. This is comparable in scale and ambition to the very welcome infrastructure investment in active and sustainable travel and highly complementary in achieving a positive impact and legacy. Over 20 million people would directly feel the benefit from this investment - nearly a third of the UK population. It would also support wider job creation, particularly in those areas of the country facing high levels of unemployment, with an estimated 40,000 jobs in initial construction and over 6,000 created permanently for ongoing maintenance.

It is important that the Government draws on social science, as changes in culture, values and behaviour in society are critical to achieving the necessary changes.


Ecological economics can provide useful insights into possible approaches for balancing economic growth and nature conservation that are additional to those provided by more widely-used environmental and neo-classical economics. Ecological economics is cross-disciplinary, linking natural and social sciences. It considers how development can be sustainable and achieve fair distribution of resources within and between generations, amongst other things (http://www.isecoeco.org/about/cross-discipline-approach/).


The Government’s pursuit of this goal would be aided by integration of the recently published ‘natural capital framework for sustainably efficient and equitable decision making’ (by Bateman and Mace) into its Green Book guidance for appraisal (https://www.nature.com/articles/s41893-020-0552-3). The framework involves adoption of sustainability rules to ensure that future generations enjoy the same wellbeing opportunities as the present generation, targets for benefits for that cannot be monetised (such as biodiversity), and it considers the efficiency of resource use. In addition to addressing inequality between generations, it is important that the Government acts to address inequality in the current generation (within and between regions in the UK). This will be aided by planned revisions to the Green Book to support ‘Levelling-up’.


Which nature-based solutions are most effective in achieving both climate and biodiversity goals?


The pursuit of climate goals must avoid perverse outcomes that harm biodiversity. For instance, monoculture plantations of trees, or even native broadleaf species could be planted in places that harm other important habitats (such as species-rich grasslands). Therefore, any trade-offs between biodiversity and climate goals should be carefully considered and unintentional damage should be avoided.


This can be achieved through strong principles for nature based solutions to climate change, which could be agreed at the international level through the CBD or the UNFCCC process. A joint memorandum between the two conventions could also help to ensure that benefits to both the climate and biodiversity are maximised.


A range of nature-based solutions also provide important biodiversity benefits. However, a mixed approach will provide the greatest range of benefits to biodiversity while also resulting in climate mitigation and adaptation. There are a range of approaches that should be used. Peatlands should be restored – at present they are a significant source of emissions (although not yet formally included in the UK’s greenhouse gas accounts) and restoring them can turn them back into carbon sinks and stores while also benefitting biodiversity. In fact, research from CPRE suggests that, unless restored, the emissions from degraded peatlands could wipe out any carbon benefits of tree planting. Tree planting can help to benefit biodiversity and the climate, but it is important to recognise that the UK’s woodland wildlife is struggling in part due to a lack of management of existing woodlands (without active management they become unsuitable for many woodland species). A mixed approach to tree cover, with the goals of benefits for the climate, people and nature, using a mix of broadleaved and softwood species (including those that will be resilient to future climate change) will provide the greatest benefits.


In some locations, it will be a combination of techniques that will benefit biodiversity and the climate: restoring rivers to their natural state, and including tree-planting, can help to provide habitat for biodiversity, improve water quality, store carbon and reduce flood risk (providing climate mitigation). Similarly, at the coast, many places are vulnerable to erosion. Restoring mudflats can help to buffer places against the effects of this, while also storing more carbon and creating invertebrate-rich habitats that waders and wildfowl can feed on.


No single nature-based solution is the most effective, but a mixed approach that allows for flexibility and adaptive management, and that prioritises the benefits to biodiversity, the climate and to people as well is the best one to adopt.


10. 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?


The success of nature-based solutions should reflect a range of outcomes that are delivered, relative to the investment made:


-          carbon stored and sequestered

-          improvements in habitats and biodiversity

-          other ecosystem outcomes, such as reduced coastal erosion or flood risk


The full benefits should always be incorporated as fully as possible alongside the costs of any nature-based solution. It is also important to recognise that nature-based solutions may take longer to begin providing some benefits (for example peatlands can take several years before they begin to sequester carbon once they have been restored) but that the ROI may be significant over the medium to long-term and more sustainable in their on-going maintenance. Nature-based solutions may also provide an equivalent or greater benefit to engineered solutions (for example coastal defences) at a lower cost, while also providing other co-benefits too.


Biodiversity and socioeconomic outcomes should be maximised and for nature-based solutions to climate change should be as important as any climate mitigation or adaptation benefits. Perverse outcomes or harm to biodiversity should be avoided – for example the use of monoculture and intensive plantations could sequester carbon, but could be detrimental to biodiversity, particularly if it replaces an existing habitat that is important for biodiversity.


11. 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?


We’d like to see the Government explore innovative fiscal measures and models which bring together public and private funding and create new investment models and opportunities to provide sustainable sources of funding over the long term. This could include exploring the role of green and blue bonds, and ways of blending public and private money. Public funds should have an explicit aim of encouraging private sector investment so that the green recovery can be sustained without always needing to resort to fresh injections of public funding through grants. 



September 2020