It was deeply disappointing that the first deed since the publication of the 25 year environment plan was Natural England’s announcement that it had consented a license to trial brood management scheme for hen harriers. 

Regular readers of this blog will be aware of the serious reservations that we have with brood management (for example see here).  This will do nothing to address the primary threat to hen harriers - illegal killing. 

Having issued our immediate reaction (here), we are currently assessing the license to consider what, if any, further action we should take.

In better news last week, we heard that heavy sentences were given to illegal bird trappers in Cyprus.  This was the culmination of surveillance undertaken by the RSPB’s Investigations team and the UK Sovereign Base Area (SBA) police. 

Our hope is that these sentences given for crimes committed on the Eastern SBA will act as a deterrent to other criminals.  As my colleague, Guy Shorrock, who was involved in the operation says in his blog “In the next couple of months we will get the results of the annual BirdLife Cyprus trapping survey: hopefully this will show a significant reduction in trapping within the ESBA”.

Wildlife crime has no place in the world in the 21st century and we must do more to stamp it out.  The 25 Year Environment Plan is clear about the role the UK will play in tackling international wildlife crime but it is silent on what it will do at home.  That needs to change.

Female hen harrier flying over Geltsdale pictured by Mark Thomas (

My colleague, Robin Wynde, has more than 25 years’ experience of influencing government biodiversity plans, and I have asked him to provide an assessment of how the 25 year plan for the environment matches our tests highlighted in my blog last week.

This is what he says…


Test 1: A compelling ambition for nature’s recovery, putting the environment at the heart of how we manage our land and sea?

The plan is not short on ambition for nature in 2043.  To ‘hand over our planet to the next generation in a better condition than when we inherited it’ (p9) is easy to say but represents a huge, but much needed, change in direction both at an England and global level.  It will need radical action and strong commitment from successive Governments.  We also welcome the commitment to recovering nature not just stopping the loss  -  ‘we will support nature’s recovery and restore losses suffered over the past 50 years.’ (p57)

The challenge will be defining what this actually means and how we can actually get there.  Adopting ‘an approach to agriculture, forestry, land use and fishing that puts the environment first’ (p9) is a great way to start and should be a key test of any future land use policy. 

For example, how will the plan work with the Clean Growth Strategy (and it is good to see links made between the two – p10) to set an ambitious carbon target for the land use sector.  We need clarity on the role and scale that the new environmental land management scheme could play in meeting such a target alongside delivering nature’s recovery.

We welcome the outline scope of the new environment land management scheme (p36-7) that Defra will develop including encouraging broad participation, retaining targeted support backed up by advice, and exploring new and innovative funding streams.  We would have liked to see a clearer statement of intent to take this scheme to another level.  Work that we have done with the National Trust and The Wildlife Trusts shows that we need to scale up funding for current land management schemes by 450% if we are to meet the challenge the environment faces in the UK and even more if we are to meet the ambitions set out in this plan for England.

We are also pleased to see reference to putting the environment at the heart of planning and development (p32) to create better places for people to live and work, particularly in urban areas. A key test of this is how the proposals on Net Gain are implemented (p32).  We welcome the action to ensure the existing requirements for biodiversity net gain in planning policy are strengthened (p34), particularly the proposed consultation on making a net gain approach mandatory.  It is essential that Net Gain is not used to fast track development at the expense of the environment. This is an area where there is scope for loss as well as gain and the devil will be in the detail. 

Test 2: Clear, measurable, stretching targets for species, habitats and protected sites including 5 year milestones to help keep progress on track?

There are ‘targets’ for each of these key components under the headline goal of ‘Thriving plants and wildlife’ (p26).  However these are not all clear or measurable or ambitious enough.  The species target refers to ‘taking action’ for threatened species (but how much and what status are we aiming for?) and lumps these in with iconic and economically important species which does nothing for clarity.

There is also a target of 75% of terrestrial and freshwater protected areas in favourable condition which compares to the current target of 50%.  It is great to see a specific target but we believe that, given the importance of this network, the work that has already been done to identify remedies and the 25 year timescale, we should be aiming at 80% or more. 

On marine protected areas there is no numeric target. This needs to be addressed as part of the first revision of the plan and we believe that we should be aiming at least as ambitious in the sea as we are on land.

However, we are very pleased by the commitment on creating or restoring 500,000 hectares of wildlife-rich habitat outside the protected site network, focusing on priority habitats (p26).

This is ambitious but, coupled with other proposals in the plan, could deliver a series of landscape scale initiatives that bring great benefits to wildlife and the health and wellbeing of local communities.  This is a target that the RSPB will be keen to contribute to during the next 25 years but experience from previous landscape scale programmes suggests that it will also need strong Government backing and support for it to succeed.

Although there are some long term targets in the plan these have not been broken down into five-year milestones, not yet anyway.

Test 3: An independent monitoring body and the ability for parliament and the public to hold the Government to account to ensure that the plan is delivered?

We are pleased to see confirmation (p139) of the commitment to consult on a ‘new, world-leading, independent, statutory body to give the environment a voice (our emphasis), championing and upholding environmental standards’.  We welcome the recognition that this body will be tasked with holding the government to account and we look forward to responding to the consultation in the near future.

We also welcome the commitment (p24) to develop, by the end of 2018, a set of metrics/indicators that will chart our progress towards a better environment, ensuring transparency and accountability. In particular, that it is clear that success of the 25 year plan will be measured by a mix of metrics that relate to the state of natural capital, the pressures on it as well as the benefits it brings.  The plan recognises very clearly that it is very difficult to put a value on the wildlife component of natural capital. It will therefore be key that the state of nature (the extent and condition of habitats and protected sites and how many species are at favourable conservation status) should be a central component for measuring the plans success.

Test 4: Robust programmes to deliver species recovery and the restoration/recreation of priority habitats?

The plan lacks any specific programme for species recovery. This is a significant omission.  There is, for example, no mention of Natural England’s species recovery programme and the impressive work that this achieved in the past.  We do not believe that a focus on habitat measures or an ecosystem approach alone will be sufficient to deliver the recovery of threatened species or the prevention of their loss or extinction.  We need the safety net of targeted species action if we are to meet one of the plans key targets.

It is great to see a specific commitment on habitat restoration/recreation (see above). We welcome the proposals (p58) to develop a Nature Recovery Network based on the ‘Lawton’ principles of more, bigger, better and connected areas for wildlife and to link this into the planning system.  We note that Defra have committed to investigate putting in place 25 new landscape scale nature recovery areas, drawing on the lessons from past experience.  We are pleased to see that although the initial focus may be on peatlands, wetlands and woodlands there is also support for important open habitats such as meadows, grasslands and heathlands. Delivery options will be considered over the next two years.  We are keen to help in this process because habitat restoration/recreation will take time and we need to get on with it to make a big difference even in 25 years.

Test 5: New sources of financing for nature conservation and ensuring that public funding supports the delivery of public goods?

We welcome the creation of a domestic natural environment impact fund (p149) to try to facilitate funding from a blend of sources and the creation of a green business council (p150) to encourage environmental entrepreneurs. We believe that such schemes should target strategically determined natural capital outcomes (which should include wildlife/nature).  However, we are aware that to date market mechanisms have delivered relatively little new money for nature conservation and we should recognise that Government will remain the primary source of financing for nature/natural capital (not just an important one) if we are to recover wildlife/biodiversity as a public good.  As the plan notes (p145) we will be publishing a paper on large scale conservation finance soon.

In a positive speech at the Oxford Farming Conference a few days before the plan launch Michael Gove set out his commitment to public money for public goods.  ‘..we will replace the BPS (Basic Payment Scheme) with a system of public money for public goods. The principal public good we will invest in is of course environmental enhancement.’ This was one of four key areas where the Secretary of State wants to drive change. We warmly welcome this and the fact that these points are included in the plan (p36). 

Test 6: Effective mechanisms for improving both access and connection to nature?

This is perhaps one of the stronger areas of the plan with some specific new proposals.  We strongly welcome the recognition of the important role that the natural environment can play in improving health and the specific proposal to launch a 3 year ‘Natural Environment for Health and Wellbeing’ programme (p74) with a cross government alliance on environment and health overseeing it) giving support for local authorities, health organisations, health professionals, teachers and planners.

We also warmly welcome the commitment (p75) to develop and fund a nature friendly schools programme that will encourage the development of nature friendly primary school grounds particularly in the most disadvantaged areas and improve connection to nature.  We believe that this should be coupled with appropriate support and training for teachers and we will be keen to contribute our ideas and experience into this programme through the proposed stakeholder engagement.  For the education proposals to have long lasting effect we remain convinced that specific legislative change to the curriculum to include instilling an ethos of looking after the environment as part of the purpose of education is a priority.

It is also good to see a commitment (p77) to review standards for the provision of green spaces. This needs to be done soon and we will then need cross government working to deliver a programme of improvements – for wildlife and for people.

Test 7: Encouragement and support for local partnerships to catalyse local delivery?

There are numerous references to partnership working throughout the plan but the section on local delivery (p139) is quite brief.  The Defra agencies have already aligned their work around 14 areas within England and developed joint statements of intent or Area Integrated Plans.  The aim is to transform these into Natural Capital Plans but there is no detail of how this will be achieved.  Local delivery includes shaping the places in which people live and getting the approach right needs to include a role for civil society and local communities.

Test 8: Action to meet our international environmental responsibilities and the adoption of a leadership role in this area?

It is good to see our international role set out in some detail (from p110).  We welcome the pledge to take a leading role in developing an ambitious post-2020 international biodiversity strategy (p120) and the recognition of the connections between the Sustainable Development Goals (SDGs) and the Paris agreement on climate change to this process. We fully support the specific statement state that future targets should be based on a robust evidence base and be ambitious, realistic and measurable (p119). Bring it on.

It is also important that this international leadership is going to be followed up at a domestic level with the publication of a new strategy for nature (for England – p58), building on the current strategy (Biodiversity 2020) and, crucially, learning lessons from it.

We strongly welcome the commitment (p125) to establishing mechanisms to screen policies and strategies for potential negative environmental effects overseas.  This is very important in minimising our global footprint and should apply to all UK Aid and foreign policies.

One key omission from this section was any mention of funding for the UK’s globally important Overseas Territories post Brexit – for example what will succeed the very important LIFE and BEST funding streams?

Test 9: Although it will be a plan for England, we need to see a commitment to develop a shared framework for environmental conservation across the four parts of the UK to ensure high standards are delivered, because nature does not recognise national boundaries

We welcome the explicit recognition that the UK Government will ‘work with the Devolved Administrations…to uphold environmental standards and go further to protect our shared natural heritage. We will continue to work with the Devolved Administrations on areas where common frameworks will need to be retained in the future.’ In addition, there is important recognition that this plan does not pre-empt the discussions. (pg 9)

We would have liked this to have gone further by setting out an ambition to work together to develop a shared vision for the future of the UK’s natural environment and deliver it in partnership. We need to do this to project our shared (and jointly created) ambition for nature on the international stage, including in our future relationship with the EU.

It is also unclear of the scope of the independent monitoring body (p139 and see above) it looks set to cover England and non devolved matters only.  We believe to should be responsible for ensuring high standards are met across the UK.

Elsewhere in the UK, in Northern Ireland the Nature Matters NI coalition have called for a 25 year plan for Northern Ireland  and RSPB Scotland have called on the Scottish Government to deliver a long-term vision for restoring nature and reboot the Scottish Biodiversity Strategy. In Wales, RSPB Cymru is working with other partners to press for effective implementation of laws and policies for nature, including the Environment (Wales) Act 2016.


So the plan ticks or partially ticks some of the tests we set out before it was published.  But as the UK Government is keen to point out, it is supposed to be a living document that will be revised within a year and then when necessary.  This is important because there are some key issues that are missing - as I said at the beinning, the plan says on combatting domestic wildlife crime.  Many of the ‘targets’ need much more clarity if they are to be properly measured and serve a purpose in driving positive change, for example those on biosecurity (p64). 

Based on Robin’s analysis, I still believe my gut instincts, expressed on the day the plan was published, are right - the plan has the potential to provide an exciting new approach to nature conservation.  Yet, lots of work is needed to ensure that it is not a false dawn, most significantly securing a new Environment Act to guarantee the ambitions are realised over the next 25 years.