Written evidence submitted by the Adaptation Sub-Committee of the Committee on Climate Change

Introduction

1. The Committee on Climate Change (CCC) was established under the 2008 Climate Change Act. The Adaptation Sub-Committee (ASC) of the CCC provides independent, expert advice on preparing for and adapting to climate change to the UK Government, devolved administrations and Parliament.

Evidence for 25-year environment plan inquiry

Consistency between 25-year Environment Plan and ASC recommendations

2. In our most recent progress report (https://www.theccc.org.uk/publication/2017-report-to-parliament-progress-in-preparing-for-climate-change/) the ASC emphasised a critical part of the next National Adaptation Programme should be to establish a long-term plan for the natural environment that takes climate change into account, builds on the level of ambition of current EU policies, and is consistent with the framework developed by the Natural Capital Committee. Furthermore, in line with the ASC's previous advice, there should be associated targets, actions, and a monitoring and evaluation framework. We have commented below on the extent to which we think these requirements are reflected in the Plan:

The Plan should take climate change into account

3. Climate Change has been given a prominent position in the Plan, with its own section and references to it throughout the report. This is positive as it highlights both the importance of addressing climate change in successfully achieving many of the goals outlined in the plan, as well as the cross-cutting nature of climate change.

The Plan should build on the level of ambition of current EU policies

4. The Plan contains high-level pledges to capitalise on the potential opportunities afforded to the UK following its departure from the EU. This includes the development of a policy statement on environmental principles to underpin policy-making post-EU Exit. Many of the domestic regulations that cover EU Directives will need amending to make sense in a domestic-only context. However, while the ASC welcomes efforts to maintain and support current environmental policy, without specific detail it is difficult to evaluate whether such pledges build on the level of ambition of current EU policies. EU directives highlighted in our 2017 progress report as being particularly important for climate change adaptation included the:

      Habitats Directive (92/43/EEC);

      Birds Directive 2009/147/EC;

      Water Framework Directive 2000/60/EC;

      Marine Strategy Framework Directive 2008/56/EC;

      Floods Directive 2007/60/EC;

      National Emissions Ceiling Directive 2001/81/EC;

      Cleaner Air For Europe Directive, 2008/50/EC.

The Plan should be consistent with the framework developed by the Natural Capital Committee

5. In line with the Natural Capital Committee’s (NCC) recommendation, the Plan is underpinned by a natural capital approach. This approach could help to facilitate better management of the UK’s environment through a better understanding of the true value of natural assets in the UK. However, generating robust values for certain natural assets is difficult, while for others it is not possible using current methods available. This is acknowledged in the Plan, and efforts to address this limitation are outlined, namely through: increased investment in research; working with the research community; and collaborating with the international community where appropriate.

The Plan should include associated targets, actions, and a monitoring and evaluation framework

6. The main gaps in the 25-Year Plan from a climate change adaptation perspective relate to its success criteria. Measuring and evaluating the success of the goals outlined requires them to be specific, measurable, achievable, results-focused, and time-bound (SMART). Out of 44 success criteria in the Plan, only 11 are SMART.  As currently set out, these success criteria will make it hard to apply proper scrutiny of the government’s performance against its objectives.

Comments in relation to specific ASC recommendations

7. Recommendation 6: Action should be taken to enhance the condition of priority habitats and the abundance and range of priority species. This action should maintain or extend the level of ambition that was included in Biodiversity 2020. An evaluation should be undertaken of Biodiversity 2020, including the extent to which goals have been met and of the implications for resilience to climate change. (Owner: Defra. Timing: by 2021).
8. In determining future action, the Plan does take into account the long-term ambition for biodiversity and wider natural capital. This is supported by the announcements of new strategies on nature, peatlands, fisheries, and the next National Adaptation Programme. However, while ambitious adaptation targets have been set for specific environmental themes many lack deadlines by which they need to be achieved. For instance, to achieve the goal of thriving plants and wildlife, there are targets to restore 75% of terrestrial and freshwater protected sites to a favourable condition. This is an important adaptation goal as set out in the Lawton Review (2010), and extends beyond the level of ambition that was included in the Government’s Biodiversity 2020 strategy. There is, however, no set deadline, and without a measureable timeframe it is hard to gauge the extent to which goals have been met, and of the implications for resilience to climate change. There are also notable gaps on targets for species recovery. And a significant proportion of the success criteria are vague, for example, “ensuring that food is produced sustainably and profitably.” As written in the Plan, it is not possible to measure progress towards these objectives.

9. Recommendation 10: To support adaptation efforts, a plan should be put in place to deliver the aspiration for all soils to be managed sustainably by 2030. The plan should include a scheme to monitor uptake of soil conservation measures, and specific proposals to reverse the ongoing loss of lowland peat soils in order to provide mitigation and adaptation benefits. (Owner: Defra. Timing: by 2019).
10. Soil protection is an essential part of the long term vision for the environment. The commitment made in the Plan to bring all of England’s soils under sustainable management by 2030 would help protect this valuable natural asset. However, the plan lacks clear pathways on how this may be done. For instance, no clear action was made in the Plan for the inclusion of the recommended schemes and proposals to provide mitigation and adaptation benefits from soils. There are also no specific proposals for a scheme to monitor the uptake of soil conservation measures or to reverse the ongoing loss of lowland peat soils. As acknowledged in the Plan, England’s drained lowland peatlands are among the nation’s most fertile soils.
11. The government indicated in its response to the ASC’s 2017 progress report it was exploring soil health issues and information on how this could support the implementation of this recommendation would be included in the 25-Year Plan. The inclusion in the Plan of policy to aid the gathering of better information on soil health and the development of a soil health index will help support this action, but does not address it in full.

12. Recommendation 11: A target for restoring all designated upland blanket bog habitats to favourable condition by 2030 should be adopted in order to contribute to both adaptation and mitigation efforts. (Owner: Defra. Timing: by 2018).
13. The ASC’s recommendation builds on the current Biodiversity 2020 target set at 50% of Sites of Special Scientific Interest in favourable condition by 2020, and 95% by area in favourable or recovering condition.
14. The condition of upland blanket bog sites is an important indication of the ability of upland peat soils to deliver various ecosystem services including carbon sequestration and improved water quality. In its response to Recommendation 11, the government agreed in principle that where appropriate upland blanket bog habitats should be restored, and indicated a strategy to support this would be included in the 25-Year Plan. While the pledge to phase out peat use altogether by 2030 as stated in the Plan is commendable and will greatly support work to restore and conserve peatlands, no clear strategy to restore the stock of upland blanket bog is provided in the plan.
15. The announced launch of an England Peat Strategy later in 2018 is a positive step and we would hope that Recommendation 11 be included as part of the strategy.

16. RECOMMENDATION 13: Policy is needed urgently to address the outstanding barriers to deliver high quality, effective [sustainable drainage system] SuDS in new development that achieve the full range of potential environmental cobenefits. In particular, there is a need for:

      More comprehensive and ambitious national standards for SuDS.

      The automatic right to connect new development to the existing sewerage network to be made conditional on the national SuDS standards being met.

      A clear policy on who should maintain and adopt SuDS by default. (Owner: DCLG. Timing: by 2019).

17. In its response to Recommendation 13, the government advised it was carrying out a review of the effectiveness of planning policies on the provision of sustainable drainage in new developments – including the strengthened policy for major development. This Review has yet to be published.
18. Actions presented in the Plan to amend Planning Practice Guidance for SuDS in new developments will help encourage their use in this area of the construction industry. However, the details on policy are vague and fall short of the ambitions outlined by the ASC’s most recent progress review.
19. We note also that the Plan does include an action to consider changes to the National Planning Policy Framework and Building Regulations in the longer term to encourage SuDS, which we would expect to be supported by the findings from the review.

Other comments

20. There is some general ambiguity over the geographical scope of the Plan. The Plan sets out the government’s approach to protecting and enhancing natural landscapes and habitats in England. However, many aspects of the Plan will apply to the UK as a whole.
21. Furthermore, the Plan sits alongside two other important UK strategies, the Industrial Strategy and The Clean Growth strategy. The Plan would benefit from more clarity over the regional level to which its respective elements will apply.
22. The Plan commits government to consulting on a new independent environmental standards body. It is unclear from the Plan alone whether this body would exist mainly to replace the enforcement functions currently provided by the European Commission and European Court of Justice, or if it would also have a role in scrutinising the 25-Year Environment Plan.  The ASC’s view is that an independent scrutiny function for the 25-Year Plan is needed in order to ensure effective, independent and objective evaluation, in the same way the ASC evaluates progress on preparing for adaptation to climate change in England.  The Committee on Climate Change is discussing with Defra how the new body could work best alongside the Committee on Climate Change. 

Further information

The ASC’s 2017 progress report can be found here, where Chapter 3 of the report covers the Natural environment and Chapter 4 covers People and the built environment. 

February 2018