RSPB – Written evidence (NSD0029)


The RSPB is the largest conservation organisation in Europe, with more than 1.2 million members. We own or manage 158,725 hectares of land on 220 reserves throughout the UK, which connect people to nature and are home to 80% of our most threatened bird species. We undertake large-scale habitat restoration and nature conservation projects, often in partnership with public and private organisations to realise benefits for nature, the environment, society, local economies and future generations. The RSPB’s policy work covers a range of issues including nature, climate change, sustainable land and marine management, agriculture and planning. Our strategy is to tackle the nature and climate emergencies together, helping to create a net-zero and nature-positive world. The RSPB is one of the leading organisations developing the evidence-base and policy solutions for Nature-based Solutions (NBS) to climate change, while showcasing best practice on the ground.


1. Potential scale of the contribution that NBS can make to decarbonisation in the UK?


NBS can deliver for biodiversity through protecting, restoring, and creating vital habitats whilst helping adapt to and mitigate climate change impacts and addressing the most pressing societal challenges. This must be done alongside, not instead of, rapid and substantial emissions cuts from fossil fuels. The RSPB/WWF report ‘The Role of Nature in a Nationally determined Contribution (NDC)’, highlights the role of different ecosystems to contribute to the UK’s climate mitigation targets and their potential to deliver additional mitigation ambition over and above BAU plans.


Protecting existing high-carbon wildlife-rich sites is a priority – RSPB mapping has shown that losing the carbon in these nature-rich places would generate around 2 Gt of carbon dioxide, equivalent to 4 years of UK greenhouse gas emissions around. However, 66% of the carbon in nature-rich areas lies outside protected areas. The RSPB’s ecosystem restoration opportunity-mapping projects, including for woodlands and peatlands, aim to understand how the restoration, protection and creation of different habitats across the UK could help store carbon. The woodlands research emphasises the significantly greater carbon sequestration from long-lived broadleaf species over short-lived conifer plantations e.g. sitka spruce. The peatlands work highlights that approximately 2.3 million hectares are in poor condition emitting the equivalent of 5% of the UK’s greenhouse gases every year – more annual emissions than all the HGVs on UK roads. The 450k ha of lowland peat agricultural soils are by far the greatest sources of emissions. Restoring peat soil function will benefit both nature and climate.


To date, tree planting has been deemed a priority intervention to sequester carbon, and this was the only approach mentioned in the UK Government’s Green Industrial Revolution. We need to increase the profile of other habitats in their role in mitigating and adapting for the impacts of climate change, and the consequences of not doing so.


Marine and coastal habitats have also been identified as valuable carbon stores. The RSPB’s Sustainable Shores report highlights opportunity areas to provide 34,250 ha of new coastal habitat in the UK. Saltmarsh stores a large volume of carbon per area and has high biodiversity value although covering a relatively small land area will limit potential for overall NBS for climate mitigation. Coastal habitats also have a high adaptation value as an NBS in coastal flooding, which will be increasingly important because of coastal squeeze. In addition, the report Towards climate-smart fisheries developed by WWF, RSPB and MCS calls for the enforcement of new and existing MPA sites that are specifically designated for carbon storage protection.


An RSPB commissioned report by Cambridge Econometrics ‘Economic benefits of nature-based climate solutions’, analyses the costs and benefits associated with restoring peatlands, saltmarsh and woodlands and demonstrates significant return on investment from these restoration activities. However, it concludes that there is currently insufficient funding for NBS in the UK to deliver the potential ecological and climate benefits.


Finally, although NBS have a crucial and valuable role to play, the UK’s climate mitigation priority must remain ending the extraction and burning of fossil fuels including in ‘hard-to-decarbonise’ sectors – NBS offer multiple benefits and deserve significant investment but are not a silver bullet for the UK’s climate mitigation challenge.


2. Major scientific uncertainties on the effects of NBS and carbon accounting


Estimates for the quantity of carbon captured through restoring natural systems varies by habitat. In the context of peat, there is robust evidence on the positive impact of rewetting and reversing damage on lowland and upland peat. There is also reasonable knowledge on the rate of tree establishment from commercial plantations, however this is often with a single/simple species mix, as opposed to the diverse mix we’d need to see for woodland regeneration where evidence is lacking.


For coastal carbon, e.g. saltmarsh, there is reasonable information on carbon storage in coastal habitats as a result of managed realignment projects, of which the RSPB has been instrumental in several including Wallasea Island and Medmerry. There is less/limited information on estimates for the:


To inform best-practice peatland restoration techniques, both upland and lowland peat need to be considered. The following bodies should be involved in establishing the agreed evidence base:


A focus on investment in negative emissions technologies could risk displacing more effective and widely beneficial carbon abatement measures, and nature restoration, which provide a host of benefits to society. Flaws in the climate accounting underlying bioenergy with carbon capture and storage gives a misleading picture of its effectiveness and may even lead to net emissions.


Under UN climate accounting rules, categorising bioenergy as carbon neutral in the energy sector relies on its emissions being accounted for when trees are harvested in the land use (LULUCF) sector. However, many countries do not fully or properly account for these land use and forest management emissions, leading to substantial emissions from biomass harvest entering the atmosphere being completely missed in climate accounts. Even if these land use emissions were to be fully accounted in the source country, importing countries are not required to acknowledge the carbon impact of this energy source where it is burned, leading to substantial misdirected carbon tax breaks and renewable energy subsidies. New analysis finds that in the case of wood pellets, bioenergy even with CCS can be a significant carbon source rather than a carbon sink for many decades. This is because offsite emissions from wood pellet processing, drying, and transport can never be captured. The analysis finds that even accounting for forest regrowth after cutting, BECCS cannot eliminate the post-harvest loss of carbon accumulation on the landscape for 30 years and, therefore, cannot deliver negative emissions by mid-century.


3. Existing frameworks for the regulation and financing of NBS


The Verified Carbon Standard (VCS) and Climate Community and Biodiversity Standard (CCB) can be used to account for carbon and biodiversity through a third-party verifier. However, there should be an accepted and universally used mechanism for combining the carbon and biodiversity benefits so that the co-benefits of interventions can be compared.


Carbon accounting mechanisms need to be able to acknowledge where an intervention may have carbon benefits across sectors, without double counting the impact. One method of achieving this would be to keep the financial instruments and the biophysical data that underpins them separate, and monitored by independent measuring, reporting and verification. The financial instrument that enables restoration to be used as offset needs to have mechanisms which are intended to ensure permanence and financial sustainability for ongoing management. This is to ensure that the carbon storage achieved/emissions reduced are not lost and could be delivered for example through conservation covenants.


Carbon offsetting can help to drive investment in nature, however, offsets can only play a small role in delivering NBS at scale as there is a risk that poor-quality offsetting schemes using NBS are a way to let industrial emitters off the hook, both reputationally and in terms of their emissions reduction commitments. Eliminating fossil fuel emission is the priority although the RSPB supports a limited role for offsets with high standards and robust safeguards in the voluntary market as part of a third party-verified net zero plan. However, this should only be utilised temporarily whilst sectors decarbonise or to compensate for the most stubborn of residual emissions. There is an unacceptable risk in promoting nature-based offsetting as part of the UK’s compliance with net zero commitments which could slow down the UK’s progress toward net zero and undermine the reliability of accounting for industrial emissions. Sectors covered by the UK Emissions Trading Scheme (UK ETS) should not be allowed to purchase external credits.


Offsetting standards should be rigorous and effective both within the Woodland Carbon Code and Peatland Code, and for any additional habitats. These should be regularly updated to keep pace with carbon accounting science and robustly implemented to ensure ecosystems and biodiversity are restored and their carbon stores are protected, including peatland soils. The Peatland Code is fundamentally different from the Woodland Code because it is derived based on surface vegetation, therefore biodiversity is implicit (rather than carbon in harvested timber in Woodland Code where biodiversity is not at the heart of it). The main carbon benefit of peatland restoration is the reduction of their current and future emissions rather than emissions drawdown.


Regarding regulation of a public-private finance model, we are aware of a patchwork of regulation frameworks for wider nature-based solutions (including non-carbon NbS). These don't need to be aligned but there would be benefits to making them inter-operable so that providers and investors can understand wider market opportunities and reduce verification costs. Regulation of hybrid public-private models will need to be layered - we would expect the FCA and other private market regulators to take a view on how investments are structured and promoted, while Government bodies will need to develop models to understand the economic value of 'crowding in' private investment. Government is likely to remain the largest investor in environmental goods and must not reduce regulatory standards in order to 'chase' uncertain private investment benefits. Delivery of NbS could regulated by existing public bodies, given the appropriate resources to expand their existing expertise.


4. Using stakeholder expertise for the implementation of NBS in the UK


NBS deployment is hindered by a lack of awareness, skills and confidence amongst landowners and managers, in addition to cultural resistance, land tenure and poor policy design. Investment in advice, training, and the facilitation of peer-to-peer knowledge transfer could help to overcome these non-financial barriers. This needs to be accompanied by investment in research into low carbon farming, including regenerative and agroecological practices to improve understanding and ensure the deployment of techniques associated with genuine emission reductions.


Funding streams need to become long-term, consistent and domestically aligned. The current funding mechanisms, such as agri-environment schemes and grants can be confusing for land managers, especially when different government funding pots are incompatible. Ensuring excellent policy design and consistency of funding is essential to the uptake of NBS and low carbon farming. Often achieving climate and biodiversity benefits requires long-term and even permanent changes in land management or farming practices


Deployment of low carbon farming techniques and habitat creation, management and restoration must be underpinned by effective and well enforced regulatory standards. Regulation has a clear and beneficial role to play in improving soil management, reducing the use, and improving the storage of nutrients which can contribute significantly to emissions, air, and water pollution. It is essential that existing gaps in regulatory standards (e.g. including soil protection) are filled and enforcement of existing standards is significantly improved and accompanied by training and support.


5. Integrating NBS with other government policies


The third series of National Adaptation Plans, required to be produced 2022-2023 following the governments’ UK Climate Change Risk Assessment due January 2022, will be a key opportunity to achieve recognition and integration for NBS as the default first-choice method of adaptation across all relevant policy areas[1].


The peatland restoration policies and action plans, all at different stages in the four devolved countries, are fundamental to drive NBS and peatland restoration.


The UK Government’s upcoming Biomass Strategy may threaten effective implementation of NBS by diverting funding and the use of land for NBS, reducing the multiple benefits that can be derived from that land alongside carbon sequestration. The best outcome for NBS via the Biomass Strategy would be to rapidly phase out UK reliance on large-scale biomass electricity, which:

  1. Exacerbates climate change over key timeframes for climate action. 
  2. Degrades forests and threatens wildlife when protecting nature is paramount.
  3. Diverts public funds to a false climate solution instead of promoting wind and solar projects built in harmony with nature, which guarantee real CO2 reductions, and more jobs, at a lower cost.


A wide range of urban and infrastructure planning policies offer enormous potential for NBS, particularly for adaptation to the impacts of climate change. These include flood defence, urban water management (e.g. for Sustainable Urban Drainage and NBS water quality treatment) urban design (e.g. greenspace for urban cooling, green roofing for cooler buildings and reducing drainage requirement)Ensuring that the upcoming Planning Bill contributes to and does not undermine efforts to reach biodiversity net gain and reduce carbon emissions will be key.


The new environmental land management (ELM) schemes in England need to provide incentives to support the deployment of NBS, including nature positive low carbon farming and the maintenance, restoration and creation of nature and carbon rich habitats. These schemes should avoid funding activities that do not have clear co-benefits for nature or could be market distorting, for example funding low diversity forestry schemes, or biofuels. There also needs to be a renewed focus on significantly changing agricultural practices on lowland peat soils to reduce, and ideally end, their major GHG contribution. Currently, the ELM schemes specifically the Sustainable Farming Incentive (SFI) lacks ambition and risks undermining efforts to transition to a low carbon farming sector. Government needs to apply the lessons learned from 40 years of agri-environment schemes.


6. Planning and monitoring NBS at a national level


Robust principles for NBS should be embedded into new/existing policies and projects, and there are a growing number of tools to enable this e.g. the NBS Guidelines provide an important standard for NBS policies. For projects, the UK Government should adopt a consistent standard that encourages projects to help compare NBS objectives and outcomes. One method the RSPB has been working with is the IUCN’s Global Standard for NBS, which have been piloting a self-assessment tool.


Reporting on NBS must be able to capture both the biodiversity and carbon benefits alongside the wider societal, economic and climate adaptation benefits. Without a standardised and scalable approach to doing this, it will be very challenging to understand collective impacts, for capacity to exist to deliver the robust monitoring required, and for initiatives to be compared over time. It’s vital to understand these factors when working towards net zero, and be able to engage transparently with the wide range of stakeholders across a variety of sectors.


Remote sensing monitoring has the capacity to help understand climate and biodiversity indicators at scale and systematically. When supported by on-the-ground verification surveys, remote sensing is a powerful tool for remotely detecting important changes in condition. This has limitations for some habitats such as grassland and detailed biodiversity monitoring (e.g. for priority species and habitats), but can provide high-level indicators required.


10 September 2021

[1] New research (in press to be published 29th Sept) from Oxford University’s Nature-based Solutions Initiative, commissioned by the RSPB and WWF, highlights the multiple opportunities for this and barriers that will need to be overcome to achieve it.