Biodiversity and Ecosystems Inquiry
About the CLA
The CLA (Country Land and Business Association) is the membership organisation for rural landowners and businesses. It has around 28,000 members who own or manage around half of the rural land in England or Wales. Although CLA members run a wide range of rural businesses the vast majority are involved in farming and it is the majority income for over half.
The CLA recommends:
The state of biodiversity:
How effectively is the Government monitoring the impact of UK activities on biodiversity, at home and abroad?
Monitoring impact on biodiversity relies on robust data collection and analysis. Although the UK has a strong record in collecting biodiversity data, there remain significant data gaps which make arriving at a true picture of the state of biodiversity difficult. Outside of protected sites and certain prominent species, there is less detailed information about the ecological health of the countryside. This makes it hard to find causal links between changes in land management practice and its impact on biodiversity. While efforts such as the regular State of Nature reports published by conservation organisations help give a picture of biodiversity in the UK, there is still only reliable data for a small proportion of species.
In terms of the impact of UK activities abroad, the lack of reliable labelling means it is not always clear to consumers the impact of imported products on the environment. A focus on the most high risk products, such as palm oil or other products that may have caused deforestation, still leaves a dearth of information about the cumulative environmental footprint of the global supply chains which British consumers use.
The CLA recommends continued investment in data gathering, the use of new technologies and development of reliable metrics and indicators to help produce a fuller and richer picture of national and global biodiversity. This does not prevent development of policies and investment in actions which we do know will benefit biodiversity based on current monitoring.
How has the Government performed against the Aichi Biodiversity Targets and what further progress is needed?
It is a matter of record that the Government’s performance against the Aichi Biodiversity Targets has been mixed. A lack of funding was identified by the Joint Nature Conservation Committee (JNCC) as one factor in the continued decline of species in the UK. There are also problems with the design and implementation of key policies, above all agri-environment schemes, which are crucial to diving changes in land management needed to meet targets. A drop-off in participation rates among farmers and land managers following the introduction of Countryside Stewardship is only just starting to reverse but uptake is still lower than the peak in 2012. Lessons must be learned for the new ELM scheme.
At the same time, cuts to Natural England’s budget have been felt in the countryside, with CLA members struggling to access the trusted, consistent local advice that can help land managers to deliver biodiversity improvements.
Where should the four nations prioritise resources to tackle biodiversity loss?
Land management plays a crucial role in achieving environmental goals, whether it is for nature, water, air quality or climate change. The role of private land managers, engaged in agriculture, commercial forestry and other rural businesses, to tackle biodiversity loss cannot be underestimated. CLA members welcome this challenge and the opportunity to play their part in restoring biodiversity but it is important that they are supported to do so by well-designed, well-funded and well-implemented policies and regulations.
Evaluating measures to conserve and enhance biodiversity:
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?
Much of the UK’s biodiversity is on privately managed land, including the large majority of land which is used for farming and agriculture. This means that Government and conservation organisations alone will not be able to achieve environmental objectives for biodiversity. They will need to work with land managers to do so and the forthcoming Environmental Land Management (ELM) scheme will be a vital policy mechanism for this.
The Government has proposed shifting the majority of the current Common Agricultural Policy (CAP) budget into the ELM scheme to pay for public goods. This will only be successful if there is a high level of uptake among farmers and land managers. This means designing an ELM scheme that is attractive and easy to enter, with the right financial incentives in place.
Academic literature and past experience show that farmers and land managers are driven by both financial and non-financial motivations to engage in environmental activity. A high level of uptake will require:
Firstly, the payment rates for ELM need to ensure that it is financially attractive when compared to other land uses. There should be clarity from the start as to how much will be paid for different actions or outcomes. Land managers need to be able to work out quickly and easily the amount of income an ELM agreement will provide so that they can decide whether it is financially viable to participate.
Secondly, the ELM scheme must ensure a simple and transparent application process and clear guidance. The current Countryside Stewardship (CS) scheme offers some lessons on barriers to participation, given the low uptake of the scheme, particularly in its early years. Compared to previous schemes, CS is overly complex, with a high administrative burden. It is crucial that the government learns from previous experiences and avoids making similar mistakes that have discouraged participation and made schemes such as CS ineffective.
Thirdly, advice and support will be crucial to encouraging land managers to participate in ELM. This includes skills and training so that land managers can understand how to deliver environmental benefits. This should result in their increased confidence in environmental management, allowing for better delivery of ELM agreements. Research has shown that developing skills in environmental management results in better deliver.
Finally, flexibility should be central to ELM. This includes flexibility over how land managers choose to deliver biodiversity and other environmental, moving towards a system of paying for the results achieved, rather than prescribing actions. There should also be flexibility to amend or expand ELM agreements over time. This would allow land managers to test what works and to increase their ambition, rather than being stuck in a contract when they could be doing more for the environment or doing it better.
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?
Taken together these measures could result in a step-change in action for biodiversity, however they need to be implemented effectively and well-funded. While biodiversity net gain and the Nature Recovery Network could complement existing policies, the reality is that the entire policy landscape relating to biodiversity is being radically re-shaped by the Environment Bill and Agriculture Bill. This offers a chance to ensure that the new system works in harmony, avoiding siloed policy making. From the point of view of land managers on the ground, who are likely to be involved and affected by the range of new policies, it is vital that they are presented with an intelligible and coherent whole, rather than piecemeal and fragmented policy and delivery.
Biodiversity net gain (BNG) represents an unparalleled opportunity to increase public acceptance of new development; deliver biodiversity gains and provide an alternative funding stream for nature conservation and improvement. If poorly implemented, however, it could result in an additional burden for rural communities and a missed opportunity to enhance the natural environment.
The CLA believes that while mandatory net gain is an important tool for biodiversity, certain exemptions or flexibility should be considered. Small development sites, especially in rural areas, already struggle to achieve financial viability, a problem which net gain could exacerbate. A net gain policy should not discourage the small-scale developments in rural villages or settlements that are required to deal with the lack of housing in the countryside. A viability test would ensure that developments could be made exempt from (or subject to a simplified version of) BNG if its application in full would render the development unviable.
The CLA supports the application of the Mitigation Hierarchy to ensure BNG does not become a ‘licence to trash’. In situations where compensatory wildlife habitat is necessary there should be a choice as to whether this is delivered within the development boundary or off-site in a nearby location. While there are social benefits to the compensatory habitat (or offset) being located near to the original site, there may well be both ecological and economic advantages to locating it elsewhere, though still within a minimum distance from the development location. Work by the Natural Capital Committee and Prof Ian Bateman has shown that trying to place BNG within the development site could lead to worse outcomes for biodiversity and blockages within the planning system. In light of this, the CLA believes that developers therefore need to be offered a choice as to how much of the total BNG requirement they place on-site and how much off-site. The new Local Nature Recovery Strategies will also be able to direct the most cost effective sites to deliver net gain.
How should Nature Recovery Networks be planned, funded and delivered?
The CLA views the Nature Recovery Network (NRN) as an organising framework that allows the principles outlined in Professor John Lawton’s review, which called for of bigger, better and more connected land for nature, to be realised.
The NRN should aim to align funding, policy and activity on the ground in order to increase the impact for nature. From a land manager’s point of view this is attractive in simplifying the otherwise complex policy and delivery landscape. There is a wide range of current and future policy aimed at nature conservation, not least the introduction of biodiversity net gain and the new Environmental Land Management (ELM) scheme. The NRN should ensure that these and other policies work together to deliver more than the sum of their parts and to focus investment and effort where it can have the most impact.
While protected sites and nature reserves offer one approach to recovering biodiversity, the NRN must recognise that what happens outside of these areas is equally important. Statutory designation of sites is often a blunt tool and can act as a block on sustainable development and economic activity, especially in rural areas. Instead the NRN should work to encourage and reward land use that is both good for nature and part of financially viable rural businesses.
Farmers and land managers are already engaged in a wide range of activities and management that is positive for nature, some undertaken voluntarily and some as part of agri-environment schemes or as part of good farming practice. There is scope for the NRN to increase both the extent of land management that is positive for nature and its impact.
This can be done by supporting better access to data, information and advice, which will allow land managers to be more aware of the impact of their activities on nature and how they can play a part in nature conservation and restoration.
Mapping where additional action could provide the most environmental impact is an important next step. The new Local Nature Recovery Strategies are an opportunity for this to be done in a uniform way, and for the resulting maps and priorities to be usable across multiple biodiversity policies, including directing where biodiversity net gain occurs and identifying priorities for the ELM scheme. However CLA members want to ensure that this mapping (and any subsequent planning of how to deliver nature restoration) is enabling and supportive, rather than prescriptive. When planning where nature recovery takes place, it is important to account for the whole range of social, environmental and economic factors in play. Some areas may be important ecologically but impractical or unsuitable for nature conservation, for example because the land has high economic value for food production.
Finally, the NRN has an important role to play in aligning and encouraging investment in biodiversity. This includes public investment through ELM, funding from net gain, water company investment and other private sources of natural capital funding. Having identified priorities for where activity will have the most impact, including by delivering multiple social, economic and environmental outcomes, it is important that a blend of public and private funding can be directed to these projects.
How effective are other policies for conservation and enhancement of existing natural habitats, such as the Woodland Grant Schemes?
The Woodland Improvement element of the Countryside Stewardship scheme, which aims to incentivise management to deliver conservation and climate change benefits, is a competitive and targeted scheme. As a result, relatively low numbers of land managers have entered into the scheme. Given the large area of unmanaged woodland, and the potential for this to deliver more for biodiversity if well-managed, there should be a focus on improving uptake and learning lessons for future schemes.
Woodland Grant Schemes would have greater reach and impact if they were more broadly accessible and the application process was simpler.
Co-ordination of UK environmental policy:
How can policy be better integrated to address biodiversity, climate change and sustainable development?
The best way to ensure integrated policy is to ensure the correct architecture and planning, something that the Environment Bill can enable. At the national level, the Bill proposes a system of environmental governance including long term environmental improvement plans and long term targets, overseen by the new Office for Environmental Protection. It is important that targets, and the planning and policy put in place to meet them, allow systematic reflection on what is needed for the environment as a whole and how this interacts with wider social and economic considerations.
A focus on a single issue, whether biodiversity, emissions reductions or economic growth, can often lead to perverse outcomes. Instead of focusing on a single issue in a vacuum, a better alternative is to focus on activity as it happens on the ground, for example focusing on particular sectors, such as agriculture, or particular geographic areas. This then allows for a holistic view of how these sectors or places can deliver across a range of environmental and economic objectives.
At a local level, and especially at the level of individual businesses or farms, it is even more important that a holistic approach is taken. We are seeing a proliferation of new policies, from ELM to biodiversity net gain to a new nature strategy. These need to be designed to complement each other, avoiding either duplication of effort or conflicting objectives on the ground.
How can biodiversity and ecosystems help achieve the air, soil and water quality objectives in the 25 Year Environment Plan?
Air, soil and water quality are three of the nine core objectives of the 25-Year environmental plan and all three benefit from land that is managed to maintain or improve its natural capital, which will also benefit biodiversity. The CLA agrees with the UK government’s overarching aim of quantifying these resources through the natural capital accounting approach. This accounting method allows for a better decision making by business and governments by directly reporting the costs of environmental degradation.
The UK government cannot reduce biodiversity loss and increase ecosystems protection without involving land managers. Sustainable and environmental land management are essential to achieve these objectives in the 25 Year Plan. Incentivising positive land management should therefore be a policy priority
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?
Farmers and land managers manage 72% of the UK’s land. As discussed above (question 4 & 10), their role in biodiversity and ecosystem protection is unquestionable. The CLA believes that there are many opportunities for land management that is both economically productive and beneficial to the environment.
Sustainable farming and forestry, including practices under the labels of agroecology and regenerative agriculture are prime examples of nature-based solutions to climate change. Regenerative agriculture has at its core the intention to improve the health of soil, which improves the quality of the ecosystem service, biodiversity and, land-productivity. Agroecology’s main aim is to maximize economic, ecological and social benefits whilst taking into account the finite resource available on the planet. The CLA agrees with these two approaches whose aim is to find a balance between financial and environmental gains.
Sustainable land management such as regenerative agriculture and agroecology produce public benefits and, as such, they should be rewarded through future environmental land management schemes. The government should invest in the agricultural industry and promote a transition towards a more sustainable, nature friendly farming. Such investment will create a multiplier effect that can result in a diversification of income streams in rural business and providing a range of economic, social and environmental benefits.
Natural capital valuations and measurement have shown that investing in maintaining and improving the natural environment has a positive cost-benefit ration. In these cases the long-term benefits of wildlife-friendly management exceeded the short-term costs. However there is still work to do to ensure that these economic benefits can be translated into financial incentives for sustainable land management.
As well as the economic benefit of environmental protection and restoration, there is also a huge value to managing our natural landscape. The UK landscape has often been shaped by agriculture and other human activities. These landscapes are valued by the public, as demonstrated by the economic value of UK tourism.
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?
As it stands, UK agriculture is highly productive, but this has often come at the expense of practices which degrade the environment. More sustainable practices which account for environmental limits will ensure agriculture is more resilient in the long term, particularly as climate change begins to have a greater impact on land management. Agroecology, for example, takes into account the surrounding natural ecosystems; integrates biological and ecological processes; and minimizes use of non-renewable inputs that harm the environment or the health of farmers and consumers. Research suggests that Investments in this area not only represent an opportunity to support and sustain the UK agriculture sector but also an unmissable chance to re-train and re-equip the rural economy to deliver environmental benefits.
The UK heavily relies on food imports as roughly half of the demand for food comes from abroad. As major food importer, the UK is exporting its environmental footprint to countries with a less regulated agriculture industry and therefore lower costs of production. In line with the UK commitment to mitigate climate change and ecosystem protections, it is important that the government creates a policy environment that promotes a more profitable sustainable farming sector and ensures that this industry is not damaged by trade deals that allow for cheap and low quality food imports. The CLA believes that investing in sustainable farming represents an opportunity to strengthen the UK’s food supply chain. Firstly, from an economic point of view, producing sustainable, high quality food is one way to boost the rural economy. Trade deals that promote cheap but low quality food imports should be therefore categorically excluded. Secondly, climate change and COVID-19 have both raised the issue of food security up the agenda. It is important that the UK continues to be able to provide food for its citizens. Thirdly, from an environmental perspective; the UK is currently exporting its carbon and environmental footprint by importing food produced to lower standards abroad.
The policy environment generated from Brexit, the current pandemic and climate change create both an opportunity and a need for a green recovery. The Government has set out an ambitious post-Brexit legislative architecture for the natural environment based on the principles of public funding for public goods, polluter pays and net environmental gain. The CLA believes now is the time to invest in a green recovery and central to this will be revitalising the rural economy by boosting public and private investment in environmental land management and nature-based solutions to climate change.
Pairing nature-based solutions to climate change with biodiversity:
Which nature-based solutions are most effective in achieving both climate and biodiversity goals?
As discussed above (question 4), biodiversity net gain represents an unparalleled opportunity to secure human well-being without exploiting the natural environment. The CLA believes that three key nature-based solutions provide the most potential to achieve climate and biodiversity goals: forestry and woodland creation and management; restoring and protecting peatland; and regenerative agriculture practices.
Forestry and woodland creation and management
Trees play an important role in the net-zero goal, sequestering and storing carbon, but for the land use sector, forestry and woodland is not currently an attractive commercial land use choice. In line with the UK government’s ‘polluters pay’ approach, the CLA believes that there should be trading scheme where large CO2 emitting sectors pay for the carbon stored in the trees to offset their own emissions, providing an ongoing income stream from the private sector for the landowner. Woodland creation and management provide plenty of other benefits including encouraging biodiversity, providing flood alleviation and improving public health through access. The CLA argues that all these benefits are public goods and it should therefore be the government responsibility to reward them through future environmental land management schemes.
The CLA supports the management and restoration of peatland to meet the needs of wildlife, people and the planet and supports the government and Committee on Climate Change targets to bring the UK’s peatland into good condition, restoration management or more sustainable management by 2040. Peatland habitats are different regionally, and even within the same geographical area there can be significant differences. Further, much of the UK’s peatland is productive agricultural land, for example the Fens in the East of England. For this reason, it is critical that any decisions on restoration are made in consultation with local landowners and are evidence-based, taking into account potential trade-offs for food production or rural tourism opportunities. Land managers in these areas are well-placed to conserve peatland and have a vested interest in ensuring the long-term biodiversity of these areas. Furthermore, peatland management undertaken by land managers, to conserve and protect wildlife represent a cost-effective way for the government to ensure these ecosystems are protected. Research show that there is insufficient conclusive evidence on the long-term impacts of different management practices for peatland, particularly as they relate to carbon storage. For this reason, it is imperative that more research and development into management practices is funded and undertaken in consultation with landowners.
Regenerative agriculture practices
Regenerative agriculture is an approach to farming that aims to improve soil health, achieving climate change, biodiversity and food production goals. With over 10 billion tonnes of carbon stored in UK soils, including grassland, arable land, peatland and forest soils, roughly equal to 80 years of annual UK greenhouse gas emissions, this is critical. Farming impacts soil health and thus soil carbon stores in both positive and negative ways, so it will be increasingly important for climate change mitigation that land is farmed in a way that maintains and increases soil carbon. How we treat the soil can impact massively on climate change – with either beneficial or detrimental consequences, depending on whether the soil is preserved or degraded – and it is therefore imperative than it is done in a sustainable and nature-friendly manner. It is the government’s responsibility to support landowners and managers and create an incentive to accelerate the transition towards sustainable agriculture.
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?
At a high level, a new national system of environmental targets, as proposed in the Environment Bill, linked to the net zero target can help measure progress and analyse trade-offs. Using a joined up and systems approach to develop both long-term and interim targets would encourage nature-based solutions that contribute to meeting several targets.
At a more granular scale, a natural capital approach could help provide a framework for judging progress and cost-effectiveness. This should be based on agreed metrics and standards that can help evaluate trade-offs and co-benefits on a project-by-project basis. This could also fit within a framework of local or regional prioritisation, for example using Local Nature Recovery Strategies to evaluate different options and find the best value for money.
It is important that this information is then presented to individual land managers and rural businesses (as well as other stakeholders) in a meaningful way. This should help make it clear how different options for changes in land management or environmental projects deliver against a range of outcomes. The new ELM scheme provides one way of using this information to incentivise actions which deliver the most co-benefits.
Finally, it is important that a holistic view of different environmental outcomes is embedded within a wider sustainable development approach, taking account of social, environmental and economic aspects. Some actions with high environmental value to both climate and biodiversity, may come at a steep economic cost. In some cases alternative income streams, for example using the ELM scheme, could incentivise environmental management or land use change on agricultural land. However, there must be ways to recognise local and national economic priorities as it is unlikely that all rural land can be used for purely environmental objectives given the pressing needs for food production, housing and other economic activity.
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?
Some nature-based solutions to climate change can be delivered through the new Environmental Land Management (ELM) scheme and other publicly-funded policies. The move towards public payments for public goods should see an increase in funding towards this type of activity. The CLA advocates payments to land managers to reflect the natural capital value of the environmental outcomes delivered and a policy designed in this way should incentivise nature-based solutions such as soil and peatland management, creating riparian habitats or woodland management and creation.
To meet the goals of the 25 year environment plan, however, will require a larger scale of investment than is possible from Government alone. The CLA has long believed there is a role for private sector investment in land management which delivers environmental and other benefits.
From the point of view of those who own or manage land, the key to success in attracting private finance is in joining up delivery mechanisms and avoiding policy silos. A natural capital approach can provide a framework to quantify the different benefits from positive land management. A single piece of land may provide carbon sequestration, flood risk prevention to local communities and businesses, biodiversity restoration and health and well-being benefits. A first step is the ability to measure and value these benefits, using credible standards and metrics as a foundation for developing markets and tradeable credits.
The ELM scheme, biodiversity net gain and private off-set schemes need to be able to operate together. This will help allow land managers to stack environmental benefits, for example seeking government funding for the public goods delivered on their land through ELM and complementing this with private investment for outcomes such as carbon sequestration on the same land. Double-funding must be avoided and this means both designing public policy and developing private markets with the knowledge that some land managers may wish to enter both.
The other important element needed is scale. Land tends to be managed in small pockets by individual owners, each one an SME. While Government has historically been prepared to enter into individual contracts with land managers to deliver environmental benefits (agri-environment schemes) the private sector, and especially larger institutional investors will be unlikely to want to bear these transactional costs. There is a role for aggregators and brokers who can act as a bridge between private investors and nature-based solutions on the ground. These business models need to be scaled up in order to attract private investment. The UK is well-placed to be a world-leader in the creation and development of environmental markets, due to our well-developed financial sector coupled with the development of new policies to support and develop these markets. The CLA supports the recommendations set out by the Broadway Initiative in their paper ‘Accelerating private investment in nature-based solutions’, which we contributed to.
 Mills, J., Land Use Policy (2018), https://doi.org/10.1016/j.landusepol.2018.02.053