(c) Stephen Magee (rspb-images.com)
Today’s blog is written by Meera Inglis, Nature Policy Officer for RSPB England, on our verdict on the newly published Environmental Improvement Plan (EIP23).
The Environmental Improvement Plan (EIP23) was published on January 31st, 2023 and is DEFRA’s first revision of the 25 Year Environment Plan (25YEP). Both documents pledge that ours will be the first generation to leave the environment in a better state than we found it.
In the lead up to EIP23’s publication, we published a series of blogs here on Nature’s Advocates, to highlight some key policies that we hoped would be included. Now that the EIP is out, this blog will look at what we asked for - and what we ended up getting – in some key policy areas.
In the first of our 25YEP blog series, which you can find here, we laid out 5 overarching things that we wanted to see in the EIP: proper funding plans; application across all 4 UK countries, integration into all Government departments, a commitment to robust data gathering and a stretching set of interim targets. We don’t have space here to address all 5 asks, but we will focus on 3: funding; integration and interim targets.
Funding
What did we want?
“[…] adequate funding needs to be provided and it must be secured for long enough to ensure the long-term viability of the various projects and policies.”
What did we get?
The EIP contains dozens of mentions of how it has provided funds to various projects over the past 5 years. However, we wanted to see what would come next and how it would be delivered. The headline initiative here is the promise to “launch the Species Survival Fund to create, enhance and restore habitats”. There is no detail on exactly how much the fund consists of, how long it will be available for, or who can apply and how. There is also a promise for a new Green Finance Strategy, which we can only hope will deliver the key details that are missing in the EIP.
Integration
“Although the 25YEP is published by DEFRA, in order to be effective its policies should be integrated across Government departments which have a direct impact on the environment.”
There are several mentions of departments working together throughout the EIP. However, what we wanted to see was a clear strategy, showing us how departments would be working and how they could be held accountable. There is one brief mention of a “cross-government 25 Year Environment Plan Board, established in 2020 to drive cross-government delivery and track and assess progress”. But there is no outline of their work so far, or details of their plans moving forward. As the OEP noted in their recent report on the 25 Year Plan; “evidence of [the board’s] impact and functions is limited. Simpler arrangements, presented in a more easily understood and standardised way, would support decision making”. As with funding, things here are quite vague.
Interim Targets
“The interim targets for 2028 must be bold and ambitious, setting us onto the right trajectory to meet long term targets in 2042. We know that front ended action will be both cheaper and more effective in meeting the long-term target goals.”
The interim targets present a mixed picture in terms of their ambition. For habitats outside of protected sites the interim target slightly front loads the creation and restoration of “wildlife rich” habitat, which is welcome, but all rests on there being a detailed delivery programme to match this.
It is also positive to see in the mix a couple of interim targets that address protected sites, and these are expressly linked to their role in helping to achieve the species targets. The interim target to ensure that all sites of special scientific interest (SSSIs) have an up-to-date condition assessment by 2028 is vital and overdue. As of early 2021, 78% of SSSIs had not had a visit to determine their condition in the previous six years. Without an accurate picture of the current state of species and habitats in these sites it is impossible to put in place the right management actions.
But the interim target that 50% of SSSIs must have actions on track to achieve favourable condition by 31 January 2028 is too weak, falling short on several accounts. Not only is this less ambitious than the earlier target set in Biodiversity 2020 (Outcome 1A) which required at least 50% of SSSIs to actually have reached favourable condition by 2020, but the most recent assessment of SSSI condition showed that this target had already been met, with 53% of the area of SSSIs in unfavourable recovering condition in 2021. The use of an action-based target, rather than an outcome focused one based on measurable on the ground improvement, is a source of concern. We will want to see this interim target further qualified when more detail is published, by adding “demonstrably” on track, or “monitoring shows they are” on track to make this clear.
So, is the EIP a failure?
The short answer is, no, it’s a mixed bag. As we pointed out in this Tweet that we put out on the day of the EIP’s publication, there are several ways in which the EIP is a step in the right direction. It puts “Thriving Plants and Wildlife” as its apex target, which shows that they understand the importance of having healthy ecosystems. It makes some good promises on Agriculture and Pesticides and it’s great to see a firm recommitment to our international obligations.
In summary, although the EIP has some good content, as our CEO Beccy Speight pointed out in this Opinion Piece for the Guardian, the time for words is over and we need action, urgently. Though the EIP promised to deliver actions (and in some places it might) it certainly doesn’t look good on funding, integration and targets.