Environment Improvement Plan

The Government published its 25 year Environment Plan in January 2018 with a commitment to review and update it every five years.  The first was published last month, The Environment Improvement Plan 2023.  It reiterates many of the targets in the original document although some of them have become somewhat less ambitious.  For example, a pledge to halve the emissions of five air pollutants by 2030 has been replaced by amended targets some of which extend to 2040.  When the Secretary of State was challenged on this, she replied that any target must be achievable.

            As in the original plan, there are ten goals in total, covering clean air and water, reducing pollution, improving the use of resources, mitigation of climate change, enhancing biosecurity and health, heritage and engagement with the natural environment.  Overarching all these is the ‘apex goal’ of thriving plants and wildlife with the pledge to halt the decline in species abundance by 2030 and then increase abundance by at least 10% of 2022 levels by 2042.  To achieve this, targets include the restoration or creation of 500,000 hectares of wildlife rich habitat by 2042, restoration or creation of 140,000 hectares of wildlife rich habitat outside protected sites by 2028 and increase woodland cover from 14.5% to 16.5% of total land area in England by 2050.  There is also the international commitment to protect 30% of land and ocean by 2030.          

            It is clear that the delivery of these targets is expected to be achieved by the Environmental Land Management Scheme (ELMS) with anticipated participation of 70% of farmers on 70% of farmland.  65% to 80% of farmers are expected to enter at least 10% to 15% of their land by 2030.  Defra, smarting from widespread criticism that the development is far too slow, announced further details last month in an attempt to accelerate the process.  The Sustainable Farming Incentive (SFI) was launched last year with three standards, arable and horticultural soils, improved grassland soils and moorland.  Six new standards have been added for 2023, double the previously expected three, covering hedgerows, integrated pest management, nutrient management, biodiversity action on arable and horticultural land, improved grassland, and low input grassland.  The three different levels for each standard have been dropped in favour of a mix and match approach designed to attract more participation by farmers.

            It is confirmed that the Local Nature Recovery tier has been scrapped and will be replaced by Countryside Stewardship, an enhanced version of the current scheme.  There is also extra payment for land managers who collaborate to deliver options over a wider area.  The top tier of ELMS, Landscape Recovery, will be expanded this year with a further 25 projects to be funded on a landscape scale.

            The critical issue, of course, is whether the level of grants will be sufficient to persuade farmers to deliver, not least because the initial uptake of ELMS has been disappointing.  It is confirmed that payment rates remain based on the income foregone principle which has been slated by George Eustice who was a Defra Minister for seven years, latterly as Secretary of State.  He described the methodology as outdated, ‘a vestige of the EU era’, and suggested that rates must be much higher if ELMS is to be successful.

            Defra is concerned that abandoning the income foregone method would not conform to WTO rules but those rules do allow an element of incentive even if that was never part of EU calculations.  Instead, to add a little more encouragement, there is a ‘management fee’ for SFI participation of up to £1,000 plus bonuses for ‘doing the right thing in the right place’.  There is also likely to be further regulation.  All those whose activities could pollute air, water or land, increase flood risk or adversely affect land drainage require an environmental permit.  At present this is restricted to companies involved in activities such as water, mining or waste but there is a potential for it to be extended to intensive livestock production.

            There are widespread concerns that funding is inadequate to achieve the targets.  The Wildlife Trusts, for example, claim that a ‘dramatic increase’ in the £1.2 billion a year budget is essential.  There is increasing funding from the private sector as companies seek to burnish their reputations.  Aviva, for example, is giving £38 million to the Wildlife Trusts to re-establish 5,200 acres of temperate rainforest in the Lake District, west Wales and west Scotland.  To encourage and regulate such investment, Defra is due to publish its Green Finance Strategy later this year.  A Land Use Framework is also expected this year in an attempt to identify where different land uses can help to achieve the goals.

            What is entirely absent from these plans and aspirations is the recognition that farming and food production is the critical element.  More food will have to be produced from less land so improving productivity is essential.  Restoring soil health and fertility is fundamental and will bring other benefits, not least to wildlife, carbon sequestration and better nutritional values of the food produced.  It appeared that this had been accepted as the initial emphasis of the SFI was on soils with the promise of a Soil Health Action Plan for England.  However, this has now been incorporated into the Environmental Improvement Plan 2023 and accounts for all of two pages in a document of 262!  A previous target of managing all soils sustainably by 2030 has been downgraded to 60% with no clear indication of how even that will be achieved.  Another flaw is the assumption that providing more habitat will halt the decline of wildlife without any recognition that other factors are involved, not least predation.

            It seems a recurring theme of this column that land use in this country and particularly our food and farming system is undergoing seismic change and yet Government has very limited understanding of the process.  Elements of Defra’s plans are heading in the right direction but an overall integrated vision and how that might be achieved is still sadly lacking.