Environmental targets at last – what has changed?
In March 2022, the government launched a consultation on environmental targets. These environmental targets are of major relevance for the UK not only because they are legally binding, but because, as the government itself pointed out in their original consultation, they will “allow for objective scrutiny and accountability of government’s progress to society”.
Despite the importance of this matter, the government failed to publish the final version of the environmental targets in October 2022, as requested in the Environment Act 2021. The importance of this delay has been explained by my colleague Jill Crawford in this article.
On Friday 16 December 2022, the government finally published the long-awaited response to its environmental targets consultation, which contains the final version of these legally binding environmental targets. The next step for the government is to publish an Environmental Improvement Plan, which is legally required to be published in January 2023.
Green groups have already published their opinions on these new environmental targets and have qualified them as providing “very little change”, being “weak and unambitious” and even being only a “job half-done”. While we do not take the same stance as these green groups, we understand their frustration as very few changes proposed by the consultation respondents were implemented in these final environmental targets.
The main question is, what are the differences between the targets proposed in the consultation (March) and the final targets (December)? In the table below, we show the main changes and provide a brief overview of relevant matters concerning these targets.
Biodiversity on land | |||
Target | Target proposed in the consultation | Final target | Overview |
2030 and long-term species abundance target | Increase species abundance by at least 10% by 2042, compared to 2030 levels | Ensure that species abundance in 2042 is greater than in 2022, and at least 10% greater than 2030 |
The precision made regarding the abundance in 2042 to be greater than in 2022 is positive. There was a well-founded concern that the original wording would allow the target to be fulfilled even if the level of species abundance that was lower in 2042 than it is today. This would happen if species abundance declined from today to 2030, because the baseline for comparison was 2030 and not 2022. The new wording provides a protection against that risk.
Several responses requested the government to increase the percentage of increase in species abundance, but the government disagreed with this proposal. While this refusal is not negative by itself, we are concerned about the reason given as the government only considered that the “increasing ambition in this way is not supported by our extensive evidence base. These targets are already challenging, and it is important that we set an achievable level.”
Irwin Mitchell provided a response to the consultation and flagged that the government has not made clear if the target of 10% is for each individual species or an average 10% across all of those monitored. If the aim of the target is to increase an average of 10% across all those monitored this would fall short of securing an increase in biodiversity. Unfortunately, this flag was not taken into consideration in the final version of the target. |
Long-term species extinction risk target | Improve the England-level Great Britain Red List Index for species extinction risk by 2042, compared to 2022 levels | Improve the Red List Index for England for species extinction risk by 2042, compared to 2022 levels |
The target remains the same. While the final target refers now to a “Red List Index for England”, this is the same document as the one mentioned in the proposed target.
Several responses requested the government to also include an indicator for species in risk of extinction. However, the government considered that “Changes in an extinction risk category for a specific species require significant improvements in the condition of the species population. Therefore, modest improvements in the overall target indicator reflect significant reductions in extinction threat […]”
While the government already made its choice, the current index is limited to only a small number of species groups and assessments are carried out on a very limited basis. We believe the index would need to be improved for example by using the IUCN Red List model to assess “Green Status”. |
Long-term wider habitats target | Create or restore in excess of 500,000 hectares of a range of wildlife-rich habitats outside protected sites by 2042, compared to 2022 levels | Restore or create in excess of 500,000 hectares of a range of wildlife-rich habitat outside protected sites by 2042, compared to 2022 levels |
The target remains the same.
The Royal Society for the Protection of Birds campaign and the Office for Environmental Protection (OEP) made a specific request to make the target a “net increase”. However, this was rejected by the Government alleging there is not enough data to fully account for habitat lost. |
Biodiversity in the sea | |||
Target | Target proposed in the consultation | Final target | Our comments |
Marine Protected Areas (MPA) target | 70% of the designated features in the MPA network to be in favourable condition by 2042, with the remainder in recovering condition, and additional reporting on changes in individual feature condition | 70% of the designated features in the MPA network to be in favourable condition by 2042, with the remainder in recovering condition |
There will be no more additional reporting on “changes in individual feature condition”. Although, the government provided in its response that they will still undertake additional reporting “on the extent to which pressures have been removed from MPAs, as part of our assessments into those features in a recovering condition.”
The OEP recommended an additional target focused on halting damaging activities by 2024. The government refused this proposal because “the target to achieve favourable condition by 2042 is predicated on halting damaging activities by 2024.” The reason for refusal is strange, because the government still agrees that damaging activities should stop by 2024. We believe this is a missed opportunity from the government to take further steps for protecting the MPAs. |
Improve water quality and availability | |||
Target | Target proposed in the consultation | Final target | Our comments |
Abandoned metal mines target | Reduce the length of rivers and estuaries polluted by target substances (cadmium, nickel, lead, copper, zinc, arsenic) from abandoned mines by 50% by 2037 against a baseline of around 1,500km | Halve the length of rivers polluted by harmful metals from abandoned mines by 2038, against a baseline of around 1,500 km |
The original wording referred only to 6 polluting metals, while the final target refers to all “harmful metals”. This is positive as it effectively expands the list of target substances.
In all the final targets, the reference to the date of compliance was changed to 2038 instead of the original 2037.
The government refused increasing the ambition alleging that “this would not be feasible given significant additional funding required, supply chain constraints and long lead-in times to secure the additional capability and to plan schemes. Ultimately, the additional costs would reduce the cost to benefit ratio”.
The pollution from a typical abandoned mine impacts not only river water, but also sediments, groundwater, and soil. We consider that not having included these media into consideration will only provide a partial picture of reality.
The consultation document in the proposed target provided ““In addition to reporting the decrease in polluted river length, we will gather data on the amount of metals captured in mine water treatment sites operated by the Coal Authority under the WAMM Programme. Prevention of these substance being discharged into rivers will provide further data and evidence in support of achieving the proposed target.” This was not mentioned again in the latest government response. We understand this means that the government will go ahead with that proposal. We disagree with this proposal, as it would involve double counting the pollution remediation (once in the source and again in the affected media). |
Nutrient pollution from agriculture target | Reduce nitrogen, phosphorus and sediment contribution from agriculture in the water environment by at least 40% by 2037 against a 2018 baseline | Reduce nitrogen (N), phosphorus (P) and sediment pollution from agriculture into the water environment by at least 40% by 2038, compared to a 2018 baseline |
Only this one word changed in the final target. The concept of pollution is different and narrower than contribution. In general terms, pollution only occurs when a certain threshold is exceeded. The government’s response did not explain the reason for this change. We hope further clarification will be provided on this change.
In all the final targets, the reference to the date of compliance was changed to 2038 instead of the original 2037.
The government refused increasing or decreasing the ambition because an increase would impact food production, while a decrease would impact the water environment. |
Nutrient pollution from wastewater target | Reduce phosphorus loadings from treated wastewater by 80% by 2037 (against a 2020 baseline) | Reduce phosphorus loadings from treated wastewater by 80% by 2038 against a 2020 baseline |
The target remains largely the same.
In all the final targets, the reference to the date of compliance was changed to 2038 instead of the original 2037.
The government refused to expand the target to include nitrogen because “further research is needed into the links between elevated nitrogen levels and eutrophic impacts in rivers nationally.” |
Water Demand target | Reduce the use of public water supply in England per head of population by 20% by 2037 | Reduce the use of public water supply in England per head of population by 20% from the 2019/2020 baseline reporting year figures, by the end of the reporting year 2037/2038 |
While the new target specifies that the baseline for comparison is 2019/2020, the target remains largely the same.
In all the final targets, the reference to the date of compliance was changed to 2038 instead of the original 2037.
A change in metric was requested because there was a concern that if population increases, then we may achieve the target even if total demand on water from the environment has increased. The government refused this change because the “distribution input over population because it indicates level of water used per person in England per day, making it relatable to water users. It will help to measure and improve water efficiency trends over time.” |
Woodland cover | |||
Target | Target proposed in the consultation | Final target | Our comments |
Tree canopy and woodland cover | Increase tree canopy and woodland cover from 14.5% to 17.5% of total land area in England by 2050 | Increase total tree and woodland cover from 14.5% of land area now to 16.5% by 2050 |
The target for woodland cover was reduced from 17.5% to 16.5%. The reason given by the government for this change is that this “is in line with our commitment in the 25 Year Environment Plan to increase woodland cover from 10% to 12% of land area by 2060, but with an expanded scope to include all trees rather than conventional woodland and brought forward to 2050 to align with the Net Zero Strategy.”
The change above went against the requests of a considerable number of respondents that actually requested to increase the target. In Irwin Mitchell’s response, we provided that in a paper published by Woodland Trust in January 2020, the Committee on Climate Change recommended a target of 19% woodland cover by 2050 if the UK is to meet its commitment to net zero by 2050. |
Resource efficiency and waste reduction | |||
Target | Target proposed in the consultation | Final target | Our comments |
Reduce residual waste target | Reduce residual waste (excluding major mineral wastes) kg per capita by 50% by 2042 from 2019 levels | Reduce residual waste (excluding major mineral wastes) kg per capita by 50% by 2042 from 2019 levels. This will be measured as a reduction from the 2019 level, which has been revised to 574 kg per capita following updated evidence postconsultation |
While the new target specifies that the baseline for comparison is the 2019 level, the target remains largely the same.
The suggestion was refused by the government as it considers that the “target is holistic and will reduce all residual waste, including plastics.” |
Air quality | |||
Target | Target proposed in the consultation | Final target | Our comments |
Annual Mean Concentration | Annual Mean Concentration Target – a PM2.5 target of 10 micrograms per cubic metre (µg per m3) to be met across England by 2040 | An Annual Mean Concentration Target for PM2.5 levels in England to be 10 µg per m3 or below by 2040. |
The target remains largely the same.
The OEP and other respondents suggested the target of 5 μg per m3, as provided in the World Health Organisation Guidance. The government refused this suggestion, alleging that 6–8 μg per m3 of the 2018 levels of PM2.5 people experienced in parts of southeast England did not come from man-made sources from the UK. Therefore, a 5 μg per m3 target would be impossible to achieve.
The OEP and other respondents suggested that the 10 μg per m3 targe was achievable by 2030 in most parts of the country. This means that that it would be more useful to have targets that are specific to local areas. The government refused this suggestion, alleging that the targets are set for England as a whole, and according to their modelling this could only be achieved by 2040. In our opinion this was a missed opportunity, as the creation of targets specific to local areas does not contradict the general target. It also seems inconsistent that the government is in favour of the inclusion of individual catchments alongside the national nutrient pollution target, but is against a local approach for air pollution. |
Population exposure reduction | Population Exposure Reduction Target – a 35% reduction in population exposure to PM2.5 by 2040 (compared to a base year of 2018) | A Population Exposure Reduction Target for a reduction in PM2.5 population exposure of 35% compared to 2018 to be achieved by 2040 |
The target remains the same.
The majority of the respondents called for greater ambition in the target. The government refused increasing the ambition alleging that “The metric and level of ambition have been determined following an evidence-based process, with input from industry and internationally recognised experts, to determine a target which is stretching but achievable, and focuses on health outcomes.” |
