Institute of Environmental Management and Assessment RNC0007
About IEMA
We are the Institute of Environmental Management and Assessment (IEMA). We are the global professional body for over 22,000 individuals and 300 organisations working, studying or interested in the environment and sustainability.
We are the professional organisation at the centre of the sustainability agenda, connecting business and individuals across industries, sectors and borders. We also help and support public and private sector organisations, governments and regulators to do the right thing when it comes to environment and sustainability-related initiatives, challenges and opportunities.
We work to influence public policy on environment and sustainability matters. We do this by drawing on the insights and experience of our members to ensure that what happens in practice influences the development of government policy, legislation, regulations and standards.
The response below is in addition to our submission to the original request for comments in 2023 (see attached). It recommends the following:
There must be a clear line of sight between targets for nature recovery and how they relate to business and their activities . There is a strong need to make nature targets ‘real’ for business so that they understand their role and the benefits for them, and that the actions they should take are clear.
Institute of Environmental Management and Assessment RNC0007
As well as return on investment not yet being clear (see IEMA’s response to this consultation in 2023, attached), there is uncertainty around the guarantee of the survival of high-integrity nature market products over time when climate change impacts such as wild fires and erratic weather can wipe out a nature investment. As yet it’s unclear what that would mean for the investor. The Government must create a system of reassurance around this to enable positive action.
The UK Green Taxonomy paper currently out for consultation mentions biodiversity once, nature three times, and ecosystems twice. However, it mentions climate fifteen times, energy ten times, and net zero nine times. If a taxonomy intends to support high-quality investments and tackle both the climate and the nature crisis, then nature must be communicated at the same level of importance as carbon removals. The UK Taxonomy must elevate nature to the same level as climate, asking participants to declare their economic activities in relation to it, then requiring them to confirm both no damage and benefits. It is important for businesses to start to see nature as an asset class of value in itself in order to prioritise action and investment.
Buyers into the nature market should be encouraged to undertake due diligence, because even for the more established providers, there is currently no way to ensure they have the long term plans secured. An organisation acting as a provider, broker or responsible body might cease to exist leaving responsibilities unfulfilled. There is a registration system for BNG units, which is a great start but there could be similar for providers themselves.
Lesley Wilson
Policy and Engagement Lead IEMA, Biodiversity and Natural Capital Institute of Environmental Management and Assessment www.iema.net
December 2024