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Letter: Defra’s environmental target proposals under the Environment Act

1. Outline

This is a letter from Lord Deben, Chair of the Committee on Climate Change and Baroness Brown, Chair of the Adaptation Committee to Rebecca Pow MP about Defra’s environmental target proposals, as required under the Environment Act. This letter offers the Climate Change Committee’s views on the consideration of climate change mitigation and adaptation within the proposed targets.

2. Key messages

  • A species abundance target expressed relative to a future reference period is likely to result in a target level below the current, heavily depleted levels.  The proposed long-term species abundance target (a 10% improvement defined relative to a currently unknown 2030 level) does not provide a clear commitment to an absolute level of species abundance that is consistent with climate-resilience. Meeting a target that would see natural ecosystems in a worse state than they are today should not be a definition of success. It would compromise resilience as well as carbon storage and be a reward for failure. This target should instead be set as an improvement over a recently defined baseline.
  • There are critical gaps in the extent and scope of the proposed targets. The proposals contain no targets related to soil health, despite this being one aspect of the natural environment highly vulnerable to climate change.  An ambitious soil health target should be included as a priority in the Government’s forthcoming Soil Health Action Plan. The woodland creation target should reflect the full range of ecosystem services supported by these habitats. Baselines and common timeframes are needed to monitor progress effectively across the targets. The target to create or restore in excess of 500,000 hectares of ‘wildlife-rich habitats’ must specify the different habitat areas it covers. Not specifying the type and extent of particular habitats that need to be restored risks overlooking some of our most important habitats.
  • The relationships between the target proposals and other Government policies must be made clearer. Delivering on the Environment Act ambition, against the background of a changing climate, requires a coordinated approach across these targets and with other policy areas. Defra should set out how the various policies for the environment and climate will fit together under the Environment Act targets. Defra has yet to set out how the Environmental Improvement Plans, the Environmental Land Management (ELM) schemes and the various policies for trees, soils and nature will fit together under the Environment Act targets.