Natural England – Written evidence (NSD0030)



Natural England is the Government’s statutory advisor on the natural environment. Our purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.


Within the UK and globally, society faces the challenges of climate change, loss of biodiversity, degradation of ecosystems and the impacts these will have on human well-being. According to the widely used IUCN definition, Nature-based solutions (NbS) are ‘actions to protect, sustainably manage and restore natural or modified ecosystems that address societal challenges effectively and adaptively, simultaneously providing human well-being and biodiversity benefits’[1]. A true NbS approach tackles climate change at the same time as supporting biodiversity and providing a wide range of benefits to people, ranging from natural flood management to opportunities for recreation. Achieving the scale of change we need to meet net zero, alongside optimising the wider benefits NbS can provide, requires a landscape scale approach, taking account of a diverse range of habitats tailored to local needs and circumstances.


Natural England recently published a comprehensive new report reviewing carbon storage and sequestration by natural habitats in England[2]. This takes an overview, looking across the full range of habitats so we can build up a clear, quantitative picture of which store most carbon, where the best opportunities are to promote carbon uptake (sequestration), and the sources of emissions from land use and management. The report is an important evidence resource to those who need to make decisions regarding NbS for climate.


While the priority must remain the decarbonisation of all sectors of the economy, NbS can tackle greenhouse gas emissions by stopping emissions from damaged habitats and starting carbon uptake by creating new habitats. NbS can also help to build resilience of both nature and people to climate change and a subset of NbS, Ecosystem-based Adaptation (EbA) is an established approach to reducing risks to people from the impacts of climate change.


We welcome the opportunity to comment on the House of Lords Science and Technology Select Committee’s important and timely inquiry into ‘Nature-based Solutions for Climate Change to assist in achieving the UK’s target of net-zero greenhouse gas emissions by 2050’ and are pleased to provide some further observations below in relation to the specific questions that the Committee have posed.


1. What is the potential scale of the contribution that nature-based solutions can make to decarbonisation in the UK?

How much of the UK’s ‘hard-to-mitigate’ emissions can be offset by nature-based solutions? How much of the UK’s land and exclusive economic zone (EEZ) coastal areas would need to be managed to achieve this, and what level of investment would be required?


1.1 Achieving ‘net zero’ greenhouse gas (GHG) emissions by 2050 will require major changes in the way we manage the land, coast, and sea, alongside decarbonisation of the energy, transport and other sectors. Ambitious emission reduction pathways shows that changes in land use and management, such as improved agricultural productivity, protection and restoration of peatlands, forestry and native woodland creation, and management of grasslands, could contribute up to 9% of the UK’s emission reduction target by 2030[3]. In 2017, emissions from agriculture, land use and peatlands were 58 MtCO2e. With ambitious steps, emissions in these sectors can be reduced by 64% to 21 MtCO2e by 2050[4] with additional savings (25 MtCO2e) from using the harvested materials from trees and energy crops for use elsewhere in the economy. Actions are identified that will mean rapid changes in farming practice and land use over one fifth of land currently used for agricultural practices.


Which ecosystems are most relevant to the UK for nature-based solutions, and which have the largest potential to sequester carbon or reduce emissions?

1.2 The largest carbon sequestration (uptake) rates amongst ecosystems are in woodlands. Native broadleaved woodlands are reliable carbon sinks that continue to take up carbon over centuries with benefits for biodiversity and other ecosystem services, although the rate varies greatly with tree species and age and is strongly influenced by soils and climate. Timber production can have benefits for climate change mitigation where wood products store carbon for the long-term or replace more fossil fuel intensive materials and fuels. It should however be noted that many non-native conifer plantations have provided little benefit to biodiversity or damaged it; going forward it is important to ensure that we only recognise as NbS those forestry systems that do benefit biodiversity as well as sequestering carbon. It should also be noted that tree planting on peatlands can lead to net greenhouse gas emissions rather than sequestration. Achieving the UK target of 30,000 ha or more of new planting could deliver emissions sequestration by 2050 of 14 MtCO2e, with an additional 14 MtCO2e from harvested materials.


1.3 Peatland ecosystems hold the largest carbon stores of all habitats. When in healthy condition they sequester carbon slowly but are unique in that they can do so for millennia. Peatlands in England have long been subjected to damaging land use, such as drainage, disturbance and burning, which has resulted in them becoming a large source of greenhouse gas emissions. The 2019 emissions reporting was the first year that a major methodology change has been incorporated to better represent emissions from peatlands. Previously a net GHG sink, this change to include peatlands more fully has resulted in the land use, land-use change and forestry (LULUCF) sector becoming a net source of emissions, with over 90% of carbon emissions from peat in England coming from peat in the lowlands managed for agriculture. Restoration interventions have been projected to reduce peatland emissions by 3.6 MtCO2e p.a. during the 6th Carbon Budget period.


1.4 Marine and coastal habitats, such as saltmarshes and seagrass meadows, have the potential to store large quantities of carbon within the sediments if undisturbed. Their vegetation can also sequester significant amounts of carbon in situ, as well as acting to trap and store carbon released from elsewhere. There are significant evidence gaps in our understanding of carbon cycling for many marine and coastal habitats and they are currently not included in the UKs GHGI. However, the protection and re-establishment of coastal habitats will also provide climate change adaptation and biodiversity benefits in addition to those for mitigation.


How do the costs and benefits (including co-benefits), of implementing nature-based solutions compare to other techniques for offsetting ‘hard-to-decarbonise’ sectors?

NbS can be very cost-effective solutions, but they vary greatly between techniques and locations, for example managed realignment at the coast can require significant engineering, whereas allowing natural colonisation of trees next to an existing wood may involve no intervention other than protection from herbivores. They also depend whether land purchase is included in costing.


2. What major scientific uncertainties persist in understanding the effects of nature-based solutions and affect their inclusion in carbon accounting, and how can these uncertainties be addressed?

How reliable are the estimates of the quantity of greenhouse gas emissions reduction or sequestration by nature-based solutions, as well as the duration and reliability of storage?

Comparing between habitats is complicated because the data have often been collected using different methods, for example there is a lack of consistency in sampling approaches or a study may vary between field survey and modelled data. Carbon stocks and sequestration rates in marine habitats are calculated differently to terrestrial habitats and include carbon originating from different sources. This makes direct numerical comparisons across habitats difficult, but necessary when attempting to understand how best to target NbS to mitigate climate change. Our recent report (see above) sets out key evidence gaps, which we summarise here.


Across all habitats, the carbon content of soils, sediments and vegetation, and greenhouse gas (GHG) fluxes are rarely measured. Even the depth of soil, vital when assessing carbon stocks, is rarely monitored. There are still large knowledge gaps for many habitats – sequestration and emissions from all habitats demonstrate variability in space and time and improved maps are needed for some habitats. For example, there is significant potential to increase carbon stocks for coastal and marine zones by re-establishing lost habitats such as saltmarsh and seagrass, but we lack numerical evidence in the English or UK context.


Further research is urgently needed to fill data gaps on carbon storage and sequestration so NbS approaches can fulfil their full potential. Natural England is leading a new pilot study of NbS for climate change at the landscape scale, on behalf of Defra and BEIS and funded by the Treasury’s Shared Outcomes Fund working with the Environment Agency, RBG Kew and the Forestry Commission, which will fill some of these gaps. Working collaboratively this work will be scientifically rigorous but also firmly rooted in the practicalities of farming and land management and will provide crucial evidence to support the government’s ambitions with the 25 Year Environment Plan and Net Zero goals. The UKRI Greenhouse Gas Removals programme will also help to fill some of these gaps


The Defra group Natural Capital & Ecosystem Assessment (NCEA) Pilot, in which Natural England is a key participant is comprehensive programme that will provide high quality (national and local) data to assess the state and condition of biodiversity, ecosystems, and natural capital assets in the terrestrial, aquatic & marine environment which will support decision making for critical environmental policies and interventions to meet the 25 Year Environment Plan. Some elements of NCEA will help decision-making on NbS and put them in a wider perspective.


Which bodies should be involved in establishing an agreed evidence base to inform best-practice techniques for restoring peatlands?

Through our work leading the Nature for Climate Peatland Grant Scheme (NCPGS), implementing the England Peat Action Plan, and decades of practitioner delivery means Natural England is well placed to play a key role in the establishment of an agreed evidence base to best-practice techniques for restoring peatlands. The NCPGS will work with land managers and stakeholders to fund landscape scale restoration work on degraded peatlands in England. The scheme aims to establish the process of restoring 35,000 hectares of degraded peat in England by March 2025, cumulatively reducing emissions from peat by 9 Mt CO2e by 2050. Other bodies that should be involved include Defra, the JNCC, Environment Agency, Forestry Commission, Forest Research, the Devolved administrations, IUCN – Peatlands, regional peatland partnerships, the Association of Drainage Boards, the Lowland Peat Agricultural Taskforce, and research institutes such as the Centre for Ecology and Hydrology. Engagement with major landowners is also vital.


To what extent do we understand the capacity of the oceans and coastal ecosystems to sequester greenhouse gases through nature-based solutions?

While it is generally accepted that marine and coastal habitats have the potential to store large quantities of carbon in their vegetation and sediments, there remains significant evidence gaps in quantifying our understanding (see 1.4 above). Often these habitats hold deep stores of carbon that represent depositional processes over decades to centuries and their protection should be prioritised. Re-establishment of saltmarsh represents the greatest potential to mitigate climate change, but is spatially limited and at risk from sea level rise. Restoration of seagrass meadows should also be considered, but data cited is typically from North America, with an understanding of the UK context lacking. Coastal ecosystems do however offer significant benefits in supporting adaptation of coastal communities to the impacts of climate change, amongst other benefits, including for biodiversity.


3. What frameworks already exist for the regulation and financing of nature-based solutions?

In addition to the Woodland and Peatland Codes mentioned below, projects funded through the Natural Environment Investment Readiness Fund and Green Recovery Challenge Fund are exploring various potential new codes which include blue carbon- seagrass, kelp and saltmarsh as well as hedgerow carbon. Other projects are exploring ways to stack environmental services and aggregate landholdings to establish projects of an investable scale.


Alongside these projects, work is underway between the public, private and NGO sectors to explore and solve the barriers to the effective operation of green finance markets that will increase the contribution that private finance makes to nature and climate recovery; examples include the Peatland Code, managed by the IUCN Peatlands Programme and the Science Based Targets Initiative (SBTI), a partnership between CDP (a non-profit climate-research provider), the United Nations Global Compact, World Resources Institute and the World Wide Fund for Nature.


This is a rapidly developing area though with a considerable number of national and local initiatives that will assist in the development of the standards and frameworks to support financing of nature-based solutions.


What can be learned from the implementation of the Woodland and Peatland Codes for the regulation and financing of nature-based solutions?

Natural England has supported the development of the Peatland Code a process that benefitted from experience gained from the earlier Woodland Code, which was promoted by the Forestry Commission). The Peatland Code is a voluntary certification standard for UK peatland projects that want to market the climate benefits of peatland restoration and provide assurance to voluntary carbon market buyers that the climate benefits delivered are additional and permanent.


The Peatland Code demonstrates that robust scientific standards are needed to demonstrate the benefits of peatland restoration, compared with the baseline of taking no action, thereby demonstrating environmental additionality. The Code also has financial and legal additionality tests that demonstrate that private finance is needed for the project to be delivered and that there are no legal or other impediments to a project.


Awareness and acceptance of the Code takes time to develop among landowners and needs sustained advocacy. This advocacy is needed from all parties involved with developing and supporting the Code. The market for peatland-based nature-based solutions is developing rapidly. The Natural England-managed Nature for Climate Peat Grant Scheme is delivering 3,000ha of peatland restoration and the resulting peat carbon unit availability will increase significantly during the project period (3 years). Natural England is using the Peat Grant Scheme and the Natural Environment Investment Readiness Fund to understand how demand for peat carbon units will develop in a growing market for carbon finance.


Are there good examples of nature-based solutions already being undertaken in the UK or elsewhere, and what can we learn from them?

There are a wide range of examples of NbS available, although not all were conceived as such and most are not at the sufficient scale that will be necessary in future. Examples include biodiverse woodland creation, managed realignment to create new intertidal habitats, peatland restoration schemes. With other public environmental bodies across the UK we are currently compiling a set of case studies which we expect to be available within the next two months.


How should a hybrid public-private financing model be regulated? How should any carbon offsetting markets be regulated to ensure that they prioritise and support well-designed and effective nature-based solutions?

The Financing Nature Coalition (public/private group) is working with the Defra Environmental Markets team to explore options for the effective operation of green finance markets. Recommendations from this work covering various areas such as governance, standards, monitoring and verification, and data as well as safeguards to avoid perverse outcomes are expected later this year and will inform various aspects of the future operation of environmental markets and the role of the public sector.


We expect it to identify the role that the public sector should have in setting standards and metrics, oversight of market operation, monitoring evaluation and verification, accreditation and reporting. It should also consider when and how the public sector can engage directly in markets, through the public estate or use of funding such as ELM.


Currently GHG emissions abatement projects such as peatland restoration are not recognised in the government’s Environmental Reporting Guidelines for use in climate-related financial disclosure. Woodland Carbon Units verified using the Woodland Code are recognised in calculating climate-related financial disclosure as they are emissions reductions, not emissions abatement. Peatland Carbon Units are traded in the Corporate Social Responsibility market, not in the compliance or voluntary markets. There is uncertainty as to how this may affect the development of what is a very young market for peat carbon units.


The Shared Outcomes Fund Project on NbS for Climate Change at the Landscape Scale includes a significant element to trial blended public / private funding mechanisms which will be starting within the next year.


How can we ensure that the carbon accountancy is science-based, robust, and consistent across nature-based solutions?

Carbon accountancy is based on recognised standards, such as the Woodland Code and the Peatland Code, which depend on good scientific evidence. The Codes allow project-specific calculations of emissions savings compared to the baseline ‘do nothing’ scenario that are robust enough to be used at national-level reporting. Codes also set scientific standards for project validation and verification so that delivery is proven by independent verifiers. Any new Codes based on habitats other than woodland or peatland must be developed by experts in those habitats with comparable scientific methods and a similar conservative approach to risk and uncertainty, namely underestimating the GHG emissions savings wherever possible.


Carbon accountancy also needs to be based on open markets and the traceable and auditable trading of credits and their retirement when they have been used for reporting. The UK Carbon Registry is an example of such as market and it is where Woodland and Peatland Carbon Units are traded.


Incentive payments for the creation of nature-based solutions are normally limited to a few years, leading to a reluctance on the part of the land-managers to undertake permanent land use change to habitats which provide these societal benefits. To really release the potential, we need to have functioning markets for ecosystem services. Whilst there is a functioning carbon market for woodlands, through the woodland carbon guarantee, markets for other habitats and other services (water, nature etc) tend to be bespoke if they exist at all and not readily available. Whilst these markets could operate within the private sector there is a clear need for Government to help steer their development and to help provide confidence in the markets about additionality and compliance.


4. Who are the key stakeholders for the implementation of nature-based solutions in the UK? How can stakeholders’ expertise and concerns inform the incentives and requirements for implementing nature-based solutions?

Key stakeholders are landowners and land managers who directly manage, as represented by individuals, businesses, the NGO / Charity sector, the Crown Estate, Ministry of Defence, water companies, government ALBs, the forestry sector and many others. Those that directly influence how land is managed are also key, and include those provide farm advice, research bodies, Internal Drainage Boards and local authorities. Engaging with a wide and diverse group of stakeholders is vital for NbS to be tailored to local needs and geography to be successful.


How can farmers (including tenant farmers) and land managers be supported in their deployment of nature-based solutions by policy and legislative frameworks?

The transition to the new Environmental Land Management schemes with the focus on ‘public money for public goods’ and delivery of a range of outcomes including mitigation of climate change will be crucial in supporting farmers and land managers to deploy nature-based solutions. Alongside financial payments it is important that land managers are supported via advice and guidance, so NbS approaches are targeted to avoid perverse outcomes, and can deliver a range of co-benefits ranging from biodiversity, water regulation, air quality, cultural heritage and landscape.


Are there examples of projects which have engaged with stakeholders and local communities to implement nature-based solutions successfully, and what can we learn from them?


Reflecting on Natural England’s delivery and practitioner experience, we can offer the following lessons as key points for what needs to be considered to deliver collaborative NbS projects successfully:


5. How should implementation of nature-based solutions be integrated with other government policies for landscapes and seascapes, for example, agricultural, forestry, and land-use planning policies?

The natural environment will play a vital role in tackling the climate crisis as healthy functioning ecosystems are needed to take up and store a significant amount of carbon in soils, sediments and vegetation. The destruction and degradation of natural habitats has resulted in a direct loss of carbon stored within them, and improved land stewardship is an essential and cost-effective carbon dioxide removal method. The conservation and restoration of natural systems can reduce net emissions at the same time as supporting and restoring biodiversity. Recent initiatives for habitat creation and restoration in England, including the Nature Recovery Network and the commitment to 500,000 ha of habitat expansion in the 25 Year Environment Plan, have the potential to make an important contribution to achieving net zero if planned strategically. The scale of land use change as described in question 1 will need to look beyond a single goal of carbon capturing and identify opportunities that deliver wider co-benefits for climate change adaptation, biodiversity, water management and soil health.


Nature-based mitigation approaches must also consider potential trade-offs with other ecosystem services as there is of conflicts resulting in impacts for land use and emission targets for decades or even centuries to come. Historic examples of this can be seen in the legacy of converting and draining peat soils for coniferous forestry plantations and intensive agriculture, and the significant GHG emissions that have resulted. By taking a strategic, integrated approach to land use change it is possible to reduce land based GHG emissions and sequester carbon whilst contributing to other priorities such as food production, climate change adaptation, for both people and nature, and biodiversity enhancement.


How could nature-based solutions implementation contribute to the UK’s goals surrounding biodiversity, the preservation of nature, and adaptation to climate change?

Climate change and biodiversity loss are closely linked problems and need to be addressed in an integrated way. Nature-based solutions offer an opportunity to achieve this. The reliance of ecosystem services, such as climate regulation, on biodiversity means that, for nature to substantially contribute to mitigation approaches will require an expansion in land cover of healthy, semi-natural habitats to increase the potential carbon sink. By looking across a range of habitats, and considering biodiversity alongside climate change mitigation Natural England’s Carbon Storage and Sequestration by Habitat 2021 (NERR094) sets out eight key principles:

  1. Protect and restore peatlands.
  2. Create new native broadleaved woodlands.
  3. Protect and restore natural coastal processes.
  4. Protect existing semi-natural habitats.
  5. Target incentives for NbS to places where they can have most benefit.
  6. Integrate NbS for climate into landscapes which are primarily devoted to agriculture or production forestry.
  7. Carry out research and monitoring to fill evidence gaps.
  8. Ensure mitigation and adaptation to climate change are planned together. This is important to ensure the durability of solutions for carbon sequestration and storage and to promote synergies rather than conflicts between objectives.


Which ongoing governmental plans, policies, and strategies are relevant to nature-based solutions, and can they be better coordinated? For example, are the Nature for Climate Fund and associated targets for peatland and forestry restoration designed so as to support nature-based solutions?

The 25 Year Environment Plan commits the government to improving the condition of our protected sites network and to creating or restoring 500,000 hectares of wildlife-rich habitat in England, as part of a Nature Recovery Network to protect and restore wildlife. The Nature Recovery Network and Local Nature Recovery Strategies can provide a framework for planning NbS within the context of protecting and restoring biodiversity


Many Government plans are relevant to NbS including: The England Tree and Peat Action Plans, Flood and Coastal Erosion Risk Management Policy and Strategy, the current Countryside Stewardship (CS) and the planned Sustainable Farming Incentive (SFI), Local Nature Recovery (LNR) and Landscape Recovery (LR) schemes, Water Industry National Environment Programme, Nutrient Neutrality and the Infrastructure and Industrial Strategies. Biodiversity Net Gain can provide opportunities for NbS and we are working on how this can deliver wider environmental benefits, including for carbon.


The Nature for Climate Fund, (N4C) is supporting woodland creation, much of which can be regarded as an NbS (see comments above about woodlands) and peatland creation, which we expect to deliver NbS in all places. A number of other programmes will also support NbS alongside a range of other outcomes, including Natural Environment Investment Readiness Fund, Flood and coast funding through both Capital programme and Resilience innovation funding, Green recovery Challenge Fund. A common theme is that it will be important to ensure that habitats created or restored under these programmes can be maintained for the long term.


Co-ordination is needed between Countryside Stewardship and N4C to ensure farmers already in CS can complement this with tree planting through N4C. The difference in funding rates between the two schemes also needs to be rationalised.


A key issue to build into future planning of NbS is climate change adaptation. It is essential to ensure that new NbS projects will remain viable in a future with higher temperatures and greater risks of droughts and floods, including through appropriate choice of species and locations. Climate change adaptation is over-looked and under-resourced compared to mitigation and this is storing up problems for the future.


Should incentives for nature-based solutions be included in future agri-environment schemes, and if so, how?

Incentives for NbS should be included in future Agri Environment Schemes. Carbon markets are developing but are not yet in a position to fund large scale implementation of NbS. It is also essential for farmers and landowners to feel confident of ongoing support in order to make long-term changes in land management. A complex array of opportunities are opening to farmers and landowners and we need a well co-ordinated approach to blending public and private funding that leads best practice and enables the right choices in the right places. Signposting and advice will be needed to realise the opportunities. Carbon storage and sequestration by the same habitat or land management practice is not uniform – they vary with a range of factors including soil type, climate and management history and farmers will require support and coordination if they are to deliver the best solutions.


Current pilot studies, including NbS for Climate Change at the Landscape Scale and the Landscape Recovery pilots, will help inform how public and private funding can be blended. Investment will follow market interests such as carbon or water quality but Government funding is likely to be needed for objectives including biodiversity, for which market mechanisms are less likely, even though this is an essential component of a healthy system. Government intervention will be needed to ensure carbon sequestration and storage schemes are true NbS, with benefits for biodiversity as well as carbon; this may be partly through regulation but financial incentive may also be necessary.


6. How should nature-based solutions be planned and monitored at the national level?

What measuring, reporting, and verification requirements should be put in place to determine the degree of success of nature-based solutions? Which techniques and technologies are best suited to accomplishing robust monitoring?

Planning will require a strategic approach, identifying where the best opportunities are for different types of NbS and where to avoid. For example, the new peat map that Natural England is producing will indicate where peatland restoration is possible, but will also indicate where tree planting should be avoided. It will also be important to integrate with biodiversity objectives and the NRN provides an obvious planning framework for this, with a local expression through Local Nature Recovery Strategies. Local scale planning is important as well as national, as many of the key spatial patterns in the physical environment and human land use can only be assessed and understood at that scale.


Monitoring is an issue that requires further work. Measuring carbon is the starting point and significant evidence gaps exist as noted above. Development is needed to allow monitoring for operational purposes as well as research techniques. Remote sensing may provide a baseline assessment of cover of different land management and uses but field survey will still be needed to provide verification and ground truthing and for sampling soil carbon and gas fluxes in a sample of locations.


It is important to emphasise that NbS is not just a land management activity that takes up carbon. It also has to benefit biodiversity to be NbS, and monitoring biodiversity outcomes of NbS initiatives is equally important. In order to deliver maximum benefit for public investment and recognise problems, it is also important to monitor the wider range of benefits to people that NbS can provide, e.g. recreation, flood protection.


10 September 2021

[1] IUCN definition

[2] Carbon Storage and Sequestration by Habitat 2021 (NERR094)