WWF is the world’s largest conservation organisation. Our mission is to stop the degradation of the planet's natural environment and to build a future in which humans live in harmony with nature by conserving and restoring the world's biological diversity, ensuring that the use of renewable natural resources is sustainable and reducing pollution and wasteful consumption
We welcome the opportunity to submit evidence to this important inquiry and would be happy to provide additional information, further testimony or an expert witness should it be helpful to the inquiry.
WWF’s Living Planet Report is a flagship publication released every two years, providing a comprehensive scientific study of global biodiversity trends and the health of our planet. 2020’s findings reveal an average 68% decline in the size of wildlife populations between 1970 and 2016 and demonstrate beyond any doubt that unsustainable human activity is overshooting the planet’s capacity for regeneration and has pushed the natural system that support life to the bring of collapse.
While the findings understandably provoke great sadness and a real sense of loss, the must also serve as a catalyst for urgent and co-ordinated action at local, devolved, national and international levels. Pioneering modelling included in this year’s report provides the first proof of concept that we can halt and reverse the trend of terrestrial biodiversity loss, but only through significant and concerted efforts, which will require substantial political will and leadership but can see nature on the road to recovery by 2030.
- Causes and consequences of global biodiversity loss
The key driver of terrestrial biodiversity loss in recent decades has been land use change and degradation, primarily the conversion of natural systems into agricultural systems, while for marine biodiversity the major threat has been overfishing. Climate change to date has not been a primary driver of biodiversity loss, but it is projected to become so, with as least one in six wild species at risk of extinction this century due to climate change alone. All drivers considered, we are destroying nature at unprecedented and unsustainable rates, with the ‘ecological footprint’ of humanity significantly overshooting the Earth’s rate of regeneration and leading to the on-going degradation of planetary health.
The loss of nature and biodiversity is not only an inherent tragedy or an environmental issue, but also a development, economic, global security, ethical and moral concern. Nature is essential for human existence and quality of life, providing food, fibre, energy and medicines, and sustaining the air, freshwater and soils on which we all depend as well as providing inspiration and cultural value to us all. It also regulates the climate, provides pollination and pest control, reduces the impact of natural hazards and can build resilience against climate change. Nature also underpins all dimensions of human health, with the destruction of natural habitats known to be a key cause of pandemics such as Covid-19.
Economic growth and development have led to extraordinary gains in human health and wellbeing and these must absolutely be celebrated. However, the overexploitation of plants and animals for economic purposes has also come at a huge cost to nature and the stability of the Earth’s operating systems that sustain us. We have stretched our safety net to breaking point, to the extent where it increasingly threatens to undermine and reverse the development and wellbeing progress made.
The Covid-19 pandemic has visibly highlighted how interlinked human health is with nature, and that as we seek to rebuild our economies, the Government should ensure all recovery spending helps us meet our climate and nature ambitions. Indeed, a prosperous, safe and resilient future is dependent upon it.
- Can biodiversity loss be halted or even reversed?
In 2017, the Bending the Curve Initiative (a consortium of WWF and more than 40 universities, conservation organisations and intergovernmental organisations) began to model potential pathways to ‘bend the curve’ of biodiversity loss - that is, to halt and then start reversing it. The Living Planet Report 2020 presents the results of this state-of-the-art modelling, which provides the first ‘proof of concept’ that we could indeed halt and reverse terrestrial biodiversity loss from land-use change.
Different ‘what-if’ scenarios were developed: a reference scenario which assumes a business-as-usual future, with alternatives designed to explore the potential consequences of various actions which could be taken to stem the tide of biodiversity loss. These interventions included: 1) increased conservation efforts; 2) more sustainable production; and 3) more sustainable consumption. These were explored individually and then in combination.
Results showed that, under a business-as-usual scenario, global biodiversity decline would continue throughout the 21st century. The pathway which was most successful, and quickest, in reversing species decline trends was the ‘integrated action portfolio’ where all interventions were pursued simultaneously. These findings provide a very clear roadmap for action: with an unprecedented and immediate focus on both conservation (including landscape restoration) and a transformation of our food system, we can both restore biodiversity and feed a growing human population.
A series of recent catastrophic events, from wildfires to locust plagues to the Covid-19 pandemic, have demonstrated more than ever before that we must conserve biodiversity not only for its inherent value but also as a non-negotiable strategic investment to preserve our health, wealth and security. The development of extensive new domestic legislation (in the form of Environment, Trade, Agriculture and Fisheries Bills) as well as upcoming major international conferences on climate, biodiversity and sustainable development, provides a once in a generation opportunity for the UK to shape the required roadmap for action, focussing in particular on conservation measures and transforming our food system.
1. THE STATE OF BIODIVERSITY
1.2. How has the Government performed against the Aichi Biodiversity Targets and what further progress is needed?
1.2.1. The UK government’s own assessment of progress shows only five of the Aichi targets are on track. Even within targets where the UK claims to be on track, there are issues:
- Although protected sites currently cover 28% of UK land area and 24% of our seas, much of these include areas that fall within the lowest level of protection as defined IUCN, for example, heavily modified and commercially used areas in National Parks. The Glover Review included a welcome challenge for protected areas to include nature recovery as part of their management plans, and WWF believes this should be implemented. Many of the UK’s protected areas, such as SSSIs include globally important sites that are in extremely poor condition.
- Many major infrastructure projects rely on a biodiversity net-gain approach to justify or excuse significant environmental harm. Application of this principle to projects such as Crossrail, HS2 and Thameslink means some of the UK’s remaining high value nature conservation sites are at risk of being damaged or lost.
1.3. Where should the four nations prioritise resources to tackle biodiversity loss?
1.3.1. Biodiversity loss is an issue that crosses national and international boundaries. Policy should reflect this reality and include support for the creation and implementation of appropriate joint frameworks.
1.3.2. At a devolved level, the Welsh Government has undertaken a significant amount of work since the Aichi Biodiversity Targets were established to tackle biodiversity loss. The bulk of this work has been around developing a series of legislative instruments which deliver frameworks intent on halting loss and setting about ‘enhancement’, exemplified by the Well-being of Future Generations (Wales) Act 2015; the Environment (Wales) Act 2016 and the Nature Recovery Action Plan. This focus on legislation and frameworks remains ongoing but means proactive effects to tackle biodiversity loss have been more limited and loss has continued. As a result, the Welsh Government must spend the next period prioritising resources towards on-the-ground delivery now that frameworks have been established.
1.3.3. WWF-Cymru suggests that the Welsh Government prioritise resources on the protection, restoration and creation of high-carbon habitats which Wales’ geography provides for. These include Peatland; Saltmarsh; Seagrass and Woodland. We recognise that systematic change is also required and that the condition of freshwater bodies in Wales is of a particular concern given how well they demonstrate wider ecosystem health. For this reason, WWF-Cymru has repeatedly called on the Welsh Government to improve freshwater condition by prioritising the end of avoidable agricultural pollution incidents and the funding of grey infrastructure removal.
2. EVALUATING MEASURES TO CONSERVE AND ENHANCE BIODIVERSITY
2.1. 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?
2.1.1. Following publication of discussion documents and initial consultation by Defra, WWF believes ELM should:
- Be more ambitious in all three tiers, with payments for taking land out of production linked to the natural capital value of the public goods delivered.
- Underpin payments through a fairly, but firmly, enforced regulatory baseline, with long-established good practice representing clear daylight to separate payments received under Tier 1 from that baseline.
- Integrate with wider agricultural, climate, environmental, land-use and planning policies.
2.1.2. A regulatory baseline must apply equally to land where managers choose not to participate in ELM as well as to scheme members in order to prevent efforts to maintain an improve biodiversity from being undermined elsewhere. Resources for enforcement need to be increased – in 2018 the Environment Agency were, on average, only making an environmental inspection visit to each farm once every two hundred years. We understand this effort has been cut further.
2.1.3. Alternative land-uses are clearly part of Defra’s proposals, and we welcome Tier 3 as the most transformative and world-leading part of ELM. This should provide coherence with the Nature Recovery Network and Local Nature Recovery Strategies, among other schemes. ELM policies should be integrated and holistic to avoid both offshoring the environmental impact of the UK food footprint and to manage domestic trade-offs, for example between afforestation and biodiversity.
2.1.4. WWF is advocating stakeholder-led processes to prioritise environmental objectives and how to optimise their delivery in respect of country and catchment plans. However, it will be important that the ELM scheme does contribute to each of the 25 Year Environment Plan goals (including thriving plants and wildlife) and local and national levels. The nature of ELM options and the payment rates/methodologies for delivering them are obviously crucial to success.
2.3. How should Nature Recovery Networks be planned, funded and delivered?
2.3.1. 25 years after the UK Biodiversity Action Plan, together with regional and local equivalents, identified species, habitats and areas for priority action for nature, UK nature remains in decline. The Nature Recovery Network(s) must not be a further exercise in more planning and no action. The Lawton and Glover reports set out the scale of action needed, the ambition required, and the commitment needed from local and national government, the private sector and civil society. There is no doubt about the urgency.
2.3.2. Government must ensure lessons and best practice are drawn quickly from the six pilot NRNs, as well as other exemplar landscapes and the biodiversity action plan process. NRNs should be supported to engage and involve stakeholders to reach consensus quickly, with a commitment to support ambition and to prioritise nature’s recovery. NRNs should not be slowed down by demands for more data and more mapping. The UK is rich in biodiversity data, from county records centres to European funded habitat mapping to county wildlife trusts. If some gaps remain, the precautionary principle should apply.
2.3.3. The Nature Recovery Network statutory guidance, due in 2021, must be ambitious and prioritise the NRN in comparison to other land uses and development. It is essential that design and delivery of NRNs is inclusive of all stakeholders and rights holders, and that local authorities are resourced and empowered through the statutory guidance.
2.3.4. Existing priority sites, including SSSIs and NNRs should be effectively restored and protected and considered part of the core of an NRN. However, to deliver on the scale required, the NRN cannot be confined to these few sites and their locales; the focus should be on a truly national network that encompasses rural, urban, coastal and marine areas across the country – supporting and connecting core sites, whilst enabling the recovery of nature though new land management opportunities at scale. These should include consideration of ‘rewilding’ approaches that apply a range of less intensive management interventions focused on supporting the establishment of natural processes and the recovery of species populations.
2.3.5. There must be a mechanism to ensure local NRNs add up, at a national level, to meaningful impact, and there must be a process for national interests to play a role in deciding local actions and priorities.
2.3.6. Other statutory processes – planning reform, agricultural payments and regulations – must be complementary to NRNs and at the least not override NRN priorities. The NRN should be integrated into other spatial plans for land use.
2.3.7. The NRN must be ecologically coherent and should promote and facilitate a landscape scale approach to planning and implementation. It is important to ensuring habitat suitability in a given location, taking account of the ecological needs of species and the need to adapt to future changes in climate and other conditions – responding to change must be built into the application of NRNs and LNRS.
2.3.8. The way the NRN is implemented and resourced will be crucial in enabling its success. There are opportunities to integrate the NRN with existing or proposed policy mechanisms, thereby maximising opportunities for spending benefits. However, Government should provide central funding that ensures effective design and delivery of the NRN. Ongoing budget restrictions for nature conservation and the responsible agencies have contributed to nature’s decline in the UK – addressing these funding gaps will be critical if NRNs are to prove effective and support the recovery of nature.
2.3.9. Where possible existing systems and processes should be mobilised to deliver the NRN in the most cost-effective way. For example, being integrated into management plans and partnership agreements for National Parks. Public bodies should also review existing plans for land and water management, including, farming and forestry, food risk management, carbon storage and adaptation to explore opportunities to deliver NRNs and meet multiple goals from existing spending plans.
3. CO-ORDINATION OF UK ENVIRONMENTAL POLICY
3.1. How can policy be better integrated to address biodiversity, climate change and sustainable development?
3.1.1. Meeting the so-called ‘triple challenge’ of people’s needs, net-zero and nature recovery requires scaled up thinking. The recovery of nature, if implemented well through resourced, supported and prioritised activities such as ELM and Nature Recovery Networks, should also deliver significant nature-based solutions to society’s needs, including storing carbon, preventing flooding and maintaining pollination among others.
3.1.2. This can only be done if local efforts – on farms, in National Parks and nature reserves, in urban areas – scale up to meaningful national achievements. These must work across local, regional and devolved governments as well as interacting with efforts to tackle the UK’s global environmental footprint. This requires catchment, regional, devolved, UK, and international vision and ambition.
3.1.3. The Agriculture Bill will be a key delivery mechanism to achieve the goals of the 25 Year Environment Plan and targets set through the Environment Bill. WWF supports the amendment to the Agriculture Bill passed on Report by the House of Lords that requires the Secretary of State to have regard to environmental improvement plans when planning the provision of financial assistance for agriculture.
3.1.4. The Environment Bill will provide a crucial legislative underpinning to set nature on the path to recovery. However, the Bill as currently drafted does not achieve the promised gold standard legislation to show global leadership for responding to the environmental crisis both at home and abroad. A major weakness is it is currently silent on the UK’s global environmental footprint (that is, the destruction of nature associated with UK consumption of imported goods). When the Environment Bill returns to Parliament, it must be strengthened to include a target for the UK’s global footprint and a legal due diligence obligation for UK businesses to assess the impact of their supply chains.
3.1.5. The Environment Bill should include an ambitious due diligence obligation on businesses and financial institutions to eliminate negative environmental and social impacts from the UK’s global supply chains.
3.1.6. We welcome the Government consultation and plans to prohibit larger businesses operating in the UK from using products grown on land that was deforested illegally. However, reliance on producer country legality alone will not be sufficient to ensure UK supply chains are deforestation and conversion free – all too often harmful deforestation is legal in producer countries, and WWF can provide further evidence on this point as required.
3.1.7. It is important that any due diligence obligation includes a statutory review in the primary legislation so that the effectiveness of the legislation can be reviewed and amendments made to ensure that the commitment to reduce the UK’s global footprint in the 25 Year Environment Plan is being achieved and that UK legislation continues to be world leading.
3.4. 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?
3.4.1. UNFCCC COP26 and CBD COP15 will decide crucial outcomes for climate, nature and sustainable development. As the incoming presidency of COP26, the UK has highlighted that nature will be one thematic priority where the UK will actively push initiatives and outcomes. In addition, the UK COP26 Presidency is looking at linkages between the climate negotiations and biodiversity negotiations in order to ramp up the global response to the interconnected climate and biodiversity emergencies.
3.4.2. As outlined above, if domestic reforms are well implemented, the UK is uniquely positioned to lead and support global action on climate, but also on biodiversity in CBD negotiations. Without ambitious outcomes and strong commitments in the CBD process, success on climate at COP26 will be made much more difficult.
3.4.3. For the UK, there is a strategic incentive to collaborate closely with China. Together, the two COP Presidencies would be able to elevate environmental issues on the global agenda. Nature-based solutions and deforestation-free supply chains, which are already being considered as domestic policy and have been highlighted by the UK as priority topics for COP26, would offer a practical bridge between the climate and biodiversity negotiations.
3.4.4. The UK, in its presidency of the UNFCCC will have a critical role over the next year in driving all parties to the Paris Agreement to enhance their ambition to get closer to the Paris ambition of keeping warming to 1.5 degrees – a level at which the worst impacts on people and nature can be averted. Credible leadership in this role will stem, in part, from the UK delivering an ambitious, net-zero aligned NDC as early as possible, and certainly this year. Integrating nature-based solutions into that NDC, and championing them as a core part of addressing the triple challenge globally will also enhance the UK’s leadership credentials at both the UNFCCC and CBD COPs’
3.4.5. To strengthen the political relevance of linking up international processes on climate and biodiversity at the highest political level, the UK could also pursue the idea of a new “Covenant with Nature”, with the CBD COP15 being a key milestone on the road towards COP26.
3.4.6. To be successful, the post-2020 Global Biodiversity Framework needs to be transformative and ambitious in terms of goals and targets, but it also needs to be comprehensive and provide all the tools for its effective and immediate implementation:
- In terms of ambition, the UK should ensure that the post-2020 framework delivers all the goals and targets needed to “bend the curve” of biodiversity loss by 2030. Reversing biodiversity loss is urgent and needed, but also doable, as demonstrated by the Living Planet Report 2020.
- A 2030 Mission should be included as part of the framework, and explicitly state “By 2030, halt and start to reverse the loss of biodiversity and put nature on a path to recovery for the benefit of all people and the planet.”
- It will also be critical for the UK to include both the direct and indirect drivers of biodiversity loss as part of the goals and targets of the Global Biodiversity Framework. The framework need to address the negative footprint of our unsustainable production and consumption patterns, and the UK should promote 2030 action targets that will transform sectors driving biodiversity loss towards sustainable activities, especially the agriculture and food sector.
- In terms of implementation, the UK should push for the establishment of an effective implementation mechanism that kicks off straight after the adoption of the Global Biodiversity Framework. This implementation mechanism would require all governments to translate the framework and its targets in relevant national planning processes, to review progress made in implementation of the framework every four years, and ramp up the delivery of plans and action at the national level through a “ratcheting” process.
4. ECONOMICS AND BIODIVERSITY
4.1. 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?
4.1.1. Investment in nature and biodiversity is a vital part of the UK 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. In Birmingham alone, for example, the net-benefit of the city’s parks and greenspaces to society is estimated at nearly £600 million; or valued at around £520 each year to each resident. The total health benefits provided by Council-managed parks and greenspaces has been valued at nearly £4.6 billion over 25 years; with the physical and mental health benefits provided by Birmingham’s Parks and Greenspaces estimated to add more than 3,300 Quality Adjusted Life Years (QALYs) each year.
4.1.2. Likewise, long term resilience in the UK economy is related to our ability to adequately mitigate and adapt to climate change. The UK Government has set a target to guide action through the Net Zero amendment to the Climate Change Act. Further understanding on the decarbonisation trajectory will be available by the end of 2020 when the Committee on Climate Change (CCC) issues advice on the 6th Carbon Budget. WWF has calculated the potential investment in nature base solutions in line with a 2050 net zero target, showing where public investment will help the UK meet our targets through nature-based solutions while supporting economic return to the UK economy.
4.1.3. For decarbonising the agricultural and land use sector, for example, this will require new economic incentives for UK farmers to introduce low-carbon agricultural practices, such as silvo-arable agroforestry. The environmental land management schemes (ELMS) can play a key role here providing here required incentives. It is worth noting that there are significant synergies between land use investment to reduce emissions, and investment to improve other forms of natural capital. The estimates presented here are narrowly focussed on decarbonisation. Estimates of investment needs to improve natural capital more broadly are provided in a recent joint NGO report on Government investment for a greener and fairer economy.
4.1.4. Aligning UK Government spending and tax decisions across the economy with net zero is one means of aligning spending and tax decisions with net zero (through mechanisms such as a net-zero test or resilience fiscal rule, for example). This is a key component of long-term economic resilience: assessing tax and spending decisions to ensure they align with carbon budgets on a trajectory to a net-zero economy by 2050; and doing so both at annual Budgets and at the Spending Review. Such an approach will be particularly crucial in the post-Covid-19 recovery, when big infrastructure investments are likely to be made. An approach which takes long term resilience into account would ensure that trade-offs and synergies between economic growth and environmental action are resilient, fair and sustainable and promote human prosperity alongside safeguarding finite nature and resources.
4.1.5. Wales has sought to address this issue with the passage of the Well-being of Future Generations (Wales) Act 2015. This places a duty on Public Bodies (including Welsh Ministers) to work towards the obtainment of seven Well-being Goals covering Economy, Society, Culture and the Environment. In practice it requires them to develop a set of Well-being Objectives which identify how they will contribute towards well-being. This process is overseen by a Future Generations Commissioner who can advise Public Bodies and report on progress on behalf of future generations in each political cycle.
4.1.6. This Act is still new, so a full assessment of its impact is yet to be completed. More needs to be done to ensure behaviour change within public bodies to use the legislative framework established by the Act as the primary driver of decision-making.
4.2. 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?
4.2.1. The Sustainable Development Goals were designed to address this very question. Built on the deliberations of a global, expert panel and co-chaired by the UK Prime Minister, in 2013, the SDGs set out a holistic framework of Goals that integrate social, economic and environmental dimensions of development.
4.2.2. The government should have its own National Plan for SDG Implementation. This should include an overarching strategy, beyond the Single Departmental Plans, to maximise policy coherence so that e.g. air pollution is managed to limit premature death or demand for health services; farming practices don’t pollute or over-abstract water-courses; green spaces are retained in cities to maximise mental health.
4.2.3. An alternative way to frame human prosperity within a finite planet is described in the concept of “Doughnut Economics”, developed and promulgated by Kate Raworth: Humanity’s 21st century challenge is to meet the needs of all within the means of the planet. The Doughnut of social and planetary boundaries is a serious approach to framing that challenge and is based on the powerful framework of planetary boundaries but adds to it the demands of social justice – and so brings social and environmental concerns together in one single image and approach. It also sets a vision for an equitable and sustainable future and it acts as a compass for human progress this century. The framework provides a compass for stakeholders to work towards shared social, environmental and economic solutions in their specific context.
4.2.4. Additional or alternative measures for GDP have been discussed over many years and would merit a separate inquiry: Robert Kennedy famously in 1968 stated “gross national product does not allow for the health of our children, the quality of their education or the joy of their play… it measures everything in short, except that which makes life worthwhile”. A small and growing number of countries are now taking on approaches that prioritise human wellbeing (see Wellbeing Economy Governments - New Zealand, Iceland, Scotland, Wales, Finland). A variety of metrics have been developed that could be used to inspire a UK “Human Prosperity Index”. These include New Zealand’s Living Standards Framework, Bhutan’s National Happiness Index; the Social Progress Index; Maryland Genuine Progress Indicator and the ONS Measures of National Wellbeing Wheel. Experience shows there is no one single indicator that can sit alongside GDP to reflect human prosperity. The UK needs to develop its social progress metrics, based on community experiences across the country.
5. Pairing nature-based solutions to climate change with biodiversity
5.1. Which nature-based solutions are most effective in achieving both climate and biodiversity goals?
5.1.1. Adopting the International Union for Conservation of Nature (IUCN) definition for nature-based solutions, any actions taken by the UK Government to address climate change must provide human wellbeing and biodiversity benefits in order to be classified as a ‘nature-based solution to climate change’. UK Government actions there must secure a positive outcome on protecting and enhancing biodiversity through any climate mitigation or adaptation action for it to be considered a nature-based solution for climate change.
5.1.2. The value or effectiveness of nature-based solution in this regard must therefore consider the wider challenges to UK landscape, including transforming the food system, limiting global warming to 1.5⁰C and securing nature recovery. Understanding the dynamics of these challenges will support resilient UK landscapes and sustainable communities and strengthen efforts to reduce our global footprint. This is a key priority in identifying which nature-based solutions will be most effective and where; and which carbon and nature hotspots need to be protected. Tools which can support the UK Government in this approach include the IUCN Global Standard on nature-based solutions, which allows for assessing and improving interventions over time and recent RSPB spatial work to map the UK’s best places for climate and biodiversity - finding that two thirds of carbon and nature rich landscapes are situated outside our protected nature sites.
 2. Mainstreaming, 11. Protected areas, 16. Implementation of the Nagoya Protocol, 17. National biodiversity strategy, 19. Mobilisation of information and research.
 See also RSPB, A Lost Decade for Nature, 2020
 Farm Inspection and Regulation Review – Interim Report (July 2018). Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/724785/farm-inspection-review-interim-report.pdf
 WWF & Vivid Economics report on net-zero transition benefits for economic recovery
 WWF & Vivid Economic report - Keeping Us Competitive