All posts by Tony Bloor

Ravens, Wildcats, Badgers, and 20,000 miles of habitat – UK wildlife is under threat

Ravens could be culled in Scotland, while badgers are threatened with mass slaughter in England…

and Network Rail chops down thousands of trees in a nationwide programme of “vegetation management”

August 28th 2018

This year has seen a number of initiatives by the UK Government in pursuit of a commitment to “leave our environment in a better state than we found it.” In January, the Government published a 25-year plan that sets out its ambitions to improve the environment within a generation [1]. In February, it launched a consultation on its proposals to replace the Common Agricultural Policy with a policy that will reward farmers for making environmental improvements [2]. And in April, new rules for farmers came into force, designed to protect water quality, reduce the risk of pollution, and prevent soil erosion [3].

In stark contrast to these plans and goals, however, the last three months has seen a licence to cull ravens in Perthshire, issued by Scottish Natural Heritage; a proposal from the UK Government to extend the cull of badgers in England; the destruction of habitat in Clashindarroch Forest in the Scottish Highlands due to logging by the Forestry Commission, which threatens the survival of the few remaining wildcats in the UK; and the destruction of large swathes of wildlife habitat across the UK by Network Rail. Whilst government ministers may voice their aspirations to “leave our environment in a better state than we found it”, the rift between rhetoric and recent activities on the ground seems glaringly obvious and shocking in its polarity.

Licence to Kill – Ravens in Scotland

On 4th April 2018, Scottish Natural Heritage issued a “research licence” to a group calling itself the “Strathbraan Community Collaboration for Waders”. The licence permitted the culling of ravens in an area of Perthshire. The reasoning behind this decision was provided a month later in a response to a petition started by Alison Lowther on, calling on Scottish Natural Heritage to stop the cull [4]. The Chair of Scottish Natural Heritage (SNH) said that wildlife legislation permits the control of birds, plants and animals, on the condition that their wider populations are not affected. Under this legislation, he continued, Scottish Natural Heritage regularly issues licences to control a range of birds and mammals including corvids (i.e., members of the crow family, which includes jackdaws, rooks, crows, and ravens):

“These activities are widespread and are carried out by farmers, gamekeepers and conservationist organisations alike in order to protect bird populations that are at risk. Curlew and lapwing are listed as Red status in the Birds of Conservation Concern (BOCC) review, with declines in abundance of over 50% in the past 20 years. They are also listed as Vulnerable at a European level. Ravens are currently on the Green list with no indication that licensed control is having any impact on the population of this species. This trial will help us and others to better understand the impact of ravens on species in grave danger.”

Alison Lowther responded with a further letter to SNH, pointing out that there was no evidence that ravens were contributing to the demise in wader populations, and that the Chair’s response provided inadequate justification for the cull. The letter was accompanied by an updated petition that had now reached over 120,000 signatures. SNH responded by treating this further letter as a formal complaint which had now reached the second and final stage of its complaints handling procedure. The final response was delivered in June by email, in which the Chair outlined further the rationale for SNH’s decision and provided further details of the licence. Further dissatisfaction, he said, would mean asking the Scottish Public Services Ombudsman to investigate the complaint.

Ravens versus Waders: A numerical problem?

The email from the SNH Chair states that the licence was granted for the purpose of “Science, Research and Education” and permits the control of “up to 69 ravens this year over an area of around 30,000 hectares.” The Chair says that SNH is confident that this will not affect the wider conservation status of ravens in Scotland on the basis of recent modelling work on raven populations undertaken on its behalf by the British Trust for Ornithology. The research project may run for up to five years, with annual reviews of its progress before granting further licences. The aim of the research is to investigate whether there is a statistical correlation between the size of the raven population and wader productivity:

“Populations of some of our wading bird species are declining rapidly. The causes of these declines are not fully understood but predation, habitat quality and climate are all likely to be important factors. Declines are largely thought to be due to low levels of productivity rather than adult survival, and studies involving the removal of predators have been shown to boost productivity.”

However, the Chair continues, many of these studies have looked at the removal of species that can either be controlled without a licence (such as foxes), or of protected species that can already be controlled under a general licence (such as crows), which means “that it can be difficult to differentiate between the relative impacts of these species and that the impacts of any other predators, including ravens, are poorly understood.” Further rationale is provided as follows:

“A correlative study looking at the relative abundance of ravens and productivity of waders found no significant relationship between the two but did find a weak negative relationship worthy of further investigation. Furthermore the data used for this study is now quite old and in the meantime the abundance of waders has decreased further, whilst raven numbers have increased…This community-led proposal aims to compare productivity of curlew, lapwing and golden plover in the study area before and after licensed reduction in raven numbers. Productivity data is also being collected outside of the licence area and the land is managed positively for waders.”

The Chair says that SNH accepts “that this proposal is not a full-scale academic study.” However, he continues, “the project is designed to help contribute to our understanding of the factors affecting wader populations, the usefulness (or otherwise) of potential interventions for their conservation, and the feasibility of these more adaptive, community-led and co-productive ways of working. This proposal is about testing an approach, on a limited scale and for a limited time-period, and adapting it if needed, in order to improve our understanding. The potential benefits of the project in this respect outweigh the impacts of the proposal on raven populations.” The Chair also states that SNH’s Scientific Advisory Committee are currently reviewing the application “and will report their findings to the SNH board who will in turn consider how best to proceed in light of that information.”

The rationale concludes on a note of desperation:

“I appreciate your concerns over this licence. However, given the plight of our waders we need, with some urgency, to look at the suite of actions available to everyone to better understand and address these declines. This is one such approach. Building on the outcome of the SAC review and some of the concerns raised over the proposal we will work with the applicant and others to ensure that we can maximise this learning without detriment to the wider raven population.”

In response, Alison Lowther submitted a complaint to the Scottish Public Services Ombudsman, who said that the decision to award the licence was now the subject of a judicial review lodged by the Scottish Raptor Study Group; the Ombudsman could not investigate the complaint due to the potential conflict with those legal proceedings.

RSPB Scotland is “outraged” by SNH decision

Meanwhile, in a blog post on the 24th of April, Duncan Orr-Ewing, RSPB Scotland’s Head of Species and Land Management, wrote: “Like so many of our supporters who have been in touch with us over the weekend, we were similarly outraged when we learned that SNH has, after some deliberation, finally decided to issue a Research Licence to local estates to cull over 60 non-breeding ravens per annum over 5 years in the Strathbraan area of Perthshire.” [5] He said that the RSPB had written to the SNH Chair, and also to the Scottish Secretary of State for the Environment, Climate Change and Land Reform, expressing its concerns over the decision. There were a number of reasons for those concerns, he said, and went on to outline the RSPB response.

Firstly, he stated the RSPB’s position on the conservation of breeding waders, which he said “is a very high priority for the work of RSPB Scotland”:

“Sadly, some of these species, notably the curlew, redshank and the lapwing have suffered large population declines in recent years. The negative factors affecting these populations of birds are well understood, and include changes in habitat as a result of some modern farming practices; afforestation of important open landscapes; as well as increasing impacts of ground predators, especially red foxes.”

He outlines the work that the RSPB is currently undertaking in this area, including the hosting of more than 4,200 pairs of breeding waders on 27 RSPB sites in Scotland, and collaborative work on private estates with sympathetic landowners. On RSPB sites, he writes, “we employ both effective habitat management and also legal predator control where necessary to conserve these important wading bird populations, and they often occur alongside healthy breeding populations of a wide variety of protected predatory birds such as raptors and ravens.”

A raptor persecution ‘black hole’ in Perthshire

Moving on to discuss the licence, he says the motive for the application is not what it seems:

“In the first instance, we doubt very much that the proposal in this case has anything to do with the given reason for the research licence request – ostensibly to ‘improve understanding of factors affecting key wader species’. In light of previous loud complaints by estates in this and other grouse shooting areas about raven predation of red grouse, we and many others see this raven research proposal as simply a rather transparent mechanism whereby a perceived pest species can be removed to benefit red grouse, with the conservation of wading birds as a by-product.”

The location for the cull, he says, should have set some alarm bells ringing amongst SNH staff, “since this area has been clearly identified by the Scottish Government, the police and other authoritative commentators for many years as a raptor persecution ‘black hole,’ where golden eagles and other protected raptors suspiciously disappear without trace or explanation”:

“Indeed, most recently SNH’s own Commissioned Report 982 published in May 2017, titled Analysis of the Fate of Satellite Tracked Golden Eagles in Scotland, clearly identified Strathbraan as one of several areas of concern across Scotland for missing golden eagles. Only last month a satellite tagged white-tailed eagle disappeared in this very location in the same circumstances to those which are identified in the above report as ‘suspicious,’ and indicative of a further wildlife crime incident. Typical moorland raptor species that used to breed in the area, such as the hen harrier, have now disappeared… In addition, our Investigations team have also encountered a number of other confirmed and suspected raptor persecution incidents in this area in recent years, all of which have been reported to the police and are documented. It worries us a good deal that SNH apparently do not seem to have taken any of this contextual information into account as part of this licensing decision.”

He also notes that red kites, although they breed and thrive close to this area of Perthshire, are notoriously unsuccessful when they try to establish breeding pairs in the central Strathbraan area.

Scottish Raptor Study Group excluded from consultation

Duncan Orr-Ewing also questions the science behind the decision, pointing out that the link between increases in raven populations and declines in breeding wading species across the British uplands is weak, as demonstrated by an authoritative study published in 2010, which was also commissioned by SNH and produced by Aberdeen University and the RSPB:

“This report also recommended that robust evidence of a predatory impact of ravens on a prey species would be needed before considering any experimental studies to test the potential impacts of raven removal. As far as we know, no such evidence has been provided, and if it has, this has not been shared with stakeholders such as ourselves.”

Finally, he says, “this licence seems to have been granted without enough consideration for collaboration and partnership, and with what appears to be some effort to exclude local organisations and individuals that could have provided expert advice and monitoring data to inform the decision in the first place.” In particular, he adds, “the Tayside members of the Scottish Raptor Study Group, who have been monitoring ravens in Perthshire for decades, were excluded from consultation.” This exclusion is reflected across other collaborative forums, he says, “where this application was only recently shared in spite of the fact that it has clearly been in development for some time with the assistance of SNH.”

He concludes by stating that any proposal to halt the decline of breeding waders, “especially where it might involve the lethal control of other predatory species,” needs to be founded on an extremely robust evidence base before such intervention is considered. Proposals also need to be deliberated in the wider context of the history of the location where such intervention is being considered, he says, especially its history relating to illegal persecution or justifiable suspicions.

RSPB Scotland: Why has SNH ignored the science?

Three days later, Anne McCall, Director of RSPB Scotland, provided an update on the situation [6]. Whilst she welcomed SNH’s decision to review the licence, she said that the latest communication from SNH provided “no information on withdrawing the licence” and no acknowledgement of raptor persecution in the location, which was a “critical omission”. She also continued to question the scientific justification for the cull, pointing to the lack of evidence for the link between raven numbers and wader productivity:

“Indeed, the most recent and relevant piece of peer-reviewed science examining any such relationship between wader declines and ravens found “no significant negative associations between raven abundance and population changes in upland waders, and so does not provide support to justify granting of licences for the lethal control of ravens in the interest of population‐level conservation of these upland wader species.” This science did identify a “weak” negative relationship between the change in raven abundance and trends of curlew and lapwing, and suggested that this relationship “may warrant further investigation.” But it also emphasized – in our view quite rightly – the importance of “making a thorough evaluation of the evidence base before making decisions regarding predator control.” In this case, it appears that SNH has done the opposite.”

She says that the RSPB had yet to see “anything approaching a robust scientific evidence base justifying the cull,” and that SNH did not allow its Scientific Advisory Committee to consider the proposal prior to issuing a licence, “instead directly proceeding to permit the killing of ravens to see what happens”:

“What’s more, from the information currently available, this cull may not take the form of a legitimate scientific experiment as currently proposed – as far as we understand there is no ‘control’ on which to monitor and properly evaluate the efficacy of this lethal act. Considering all of the above, RSPB Scotland maintains that there is no justification for this extreme course of action, and will continue to pursue that SNH withdraw this licence. Alternatively, the option is always open for those who have sought the licence to voluntarily pause any culling in order to allow time and space for the SNH Scientific Advisory Committee to conduct a thorough and meaningful analysis. Choosing not to pause a cull in order to make sure the science is in order has to beg the question, why on earth is this being done at all?”

Last month, BBC News reported that the licence had been suspended following the review by SNH’s Scientific Advisory Committee, which found that the project “was inadequate at providing robust scientific conclusions” [7]. Kevin Keane, BBC Scotland’s environment correspondent, reported that the committee has made a series of recommendations which will be incorporated into the terms of the licence. The “Strathbraan Community Collaboration for Waders” has volunteered to suspend the project until the new licence is drawn up.

Licence to Kill – Swifts and Robins?

Last week, however, the RSPB reported that it had received several enquiries over the last few weeks regarding licences issued by Scottish Natural Heritage for otherwise protected birds including swifts, robins, and others [8]. On the killing of swifts, it said it was initially struggling to find a legitimate reason for the licence:

“What serious threat to public health is posed by this endangered species that requires indefinite numbers of them to be killed?… It does seem possible that the licence applicant has mistaken swallows for swifts and that SNH has not realised this. Apparently, there has been an issue of birds nesting in safety critical equipment at an airfield and removal of the nests is what has been intended.”

In the case of swallows, the RSPB says that if the action taken is confined to the early removal of nests before the swallows lay eggs, “then this does start to look a bit more proportional. Swallows will readily relocate if discouraged from nesting in the early spring. Swifts, however, have very strong nest site fidelity and are much less flexible.” More openness from SNH, it says, would help to answer many unanswered questions by allowing licenses to be subject to a better-informed public scrutiny: “For example, is it really always necessary to kill any robin that ends up in a food store? Killing is supposed to be the option of last resort, not the standard procedure.”

Mass Slaughter – Badgers in England

An issue that has attracted widespread coverage in the national press is the culling of badgers, which Defra (the Department for the Environment, Food & Rural Affairs) says is necessary as part of a 25-year strategy to eradicate the spread of bovine TB. Environmental campaigners have argued that there is no evidence that the culling of badgers is effective in combating the spread of TB and that vaccination of badgers and cattle should be the priority. Despite expert advice, however, and despite the fact that killing badgers does not prevent the spread of the disease from cattle to cattle, the Government has persisted in trials of the cull in an increasing number of English counties. BBC News reported in March that around 20,000 badgers were culled in eight counties in 2017 [9]. The cull took place in 19 locations in Gloucestershire, Somerset, Dorset, Devon, Cornwall, Herefordshire, Cheshire, and Wiltshire. Culling started in 2013 in Somerset and Gloucestershire, in 2015 in Dorset, and in 2016 in Devon, Cornwall, Herefordshire, and another location in Gloucestershire. The licences allow badgers to be killed every year between 1 June and 31 January.

In May, the Government announced plans to expand its badger culling program this autumn, with farmers being offered a £50 bounty for each animal killed [10]. Natural England had announced earlier that it had already received new licence applications or “expressions of interest” from nine locations in or near areas of “high risk,” situated in Avon, Berkshire, Derbyshire, Hampshire, Oxfordshire, Shropshire, Staffordshire, Warwickshire, and Wiltshire [11]. News of the cull expansion prompted another petition on, started by Lee Jenkins, calling on Environment Secretary Michael Gove to stop the cull [12]. The petition had attracted over 200,000 signatures by the time it was delivered in July. On the Government’s proposals, Lee Jenkins said:

“Over 50,000 badgers were culled by farmers in the last two years, and if we keep on going this way it will have a serious impact on our environment. In the past, wolves, lynxes and wild boars were hunted to extinction and are now having to be reintroduced – why are we repeating the same mistakes again with the badger? The government says this is part of a program to stop the spread of bovine TB, but previous trials of culling badgers have not successfully stopped the disease. Vaccinations would be a far more ethical way of stopping TB, along with increased hygiene measures in farms. Badgers are an iconic symbol of the British countryside, and killing them will leave a huge hole in the ecosystem and do long term damage to our environment.”

Having spoken to farmers, Lee Jenkins says that some farmers in Somerset have released rescued badgers onto their farms. Rescued badgers are vaccinated before they are released and will keep other badgers off their territory as they are very territorial, he says, which demonstrates that vaccination works.

News of the proposed cull extension was reported in the Daily Mail way back in February [13]. Professor Rosie Woodroffe, senior research fellow at the Institute of Zoology, is quoted as saying:

“Defra is considering licensing more than 10 new areas a year, so the total cull zone would start to engulf entire counties, and the numbers of badgers killed each year would climb into the many tens of thousands. Slaughtering wildlife on this scale needs to be well justified – unfortunately there is not yet robust evidence that the current badger culling policy is helping to control cattle TB.”

Environmental campaigners continue to argue that the main reason for the spread of TB in cattle is contact from cattle to cattle; not via badgers. The Wildlife Trusts point out that cattle in the UK are already vaccinated for up to 16 diseases, but the Government has failed to develop one for TB [14]. It says that 25% of the European badger population is found in the UK, and we therefore have an international responsibility to conserve them. In contrast, the current policy of mass slaughter could see the badger threatened with extinction.

Habitat Destruction – Wildcats in Scotland

Meanwhile, in the Highlands of Scotland, campaigners are working to save another animal from extinction: the Scottish wildcat. In May, wildlife photographer Steve Piper started a petition on calling on the Scottish Environment Minister to prevent logging by Forestry Commission Scotland in a location that provides a home for 13 of the UK’s dwindling wildcat population [15]. The Scottish wildcat is only found in Scotland, and according to Steve Piper the total population is estimated to be around 35, making it “one of the world’s rarest wild animals.”

Ten years ago, Steve Piper set up a project to conserve the Scottish wildcat, called Wildcat Haven [16]. Field work by the project established a count of 13 wildcats living in Clashindarroch Forest in Aberdeenshire, some miles north-east of the Cairngorms, and some miles likewise from those well-known glens, Glen Fiddich and Glen Livet. Steve Piper says that the forest also provides a home for red squirrels, pine martens, and goshawks, and is the wildcat’s last and only known major stronghold and breeding site, “but logging is taking place in the middle of the kitten season, disturbing wildcat mothers, which could make them abandon or even eat their young.” Logging by Forestry Commission Scotland has failed to identify territories, he says, which have been felled as a result, creating a disturbance during the breeding season that goes against the legislation that protects wildcats and their habitat.

By June, the petition had reached 200,000 signatures, but news emerged of plans to install two wind farms in the forest, one by Fred Olsen, the details of which were unknown, and one by Vattenfall, which would extend an existing wind farm by clear felling 1560 hectares of Clashindarroch Forest, about a quarter of the whole. Steve Piper said that there are many other locations in the area that are suitable for wind turbines, and that the company’s plans clearly show that the turbines will cut the forest in half, and that the 1560 hectare site is almost all forestry, “including some ancient woodland immediately where the turbines are to be sited.” In its plans, the company also said that clear felling will be carried out at the appropriate time [17].

Wildcat Haven questions the claim that felling can benefit the wildcat population

Responding to these developments, Wildcat Haven wrote a letter at the end of June to Scotland’s First Minister Nicola Sturgeon, expressing its concerns over the work currently being carried out by Forest Enterprise Scotland, on behalf of the Forestry Commission, and its concerns over the wind farm proposals. The letter states:

“As required, Forest Enterprise Scotland (FES) do appear to be carrying out pre-felling surveys to check for wildcat presence. However, it has been proven that those surveys have failed to identify wildcat territories which were subsequently felled… In one case, FES were shown evidence of a wildcat on a site already being clear-felled. They briefly ceased operations accepting the cat was present, then continued clear-felling anyway… An FES species ecologist commented that ‘cats can move,’ even though the law expressly forbids this happening. He is also the only ecologist we are aware of with the opinion that forcing the movement of highly territorial, legally protected, and critically endangered animals is no big deal.”

The letter also casts doubt on the science behind the claim by Scottish Wildcat Action that wildcats benefit from 90 hectares of their territory being clear-felled. The letter states: “There is absolutely no evidence that Scottish wildcats benefit in any way from clear-felling, and a considerable body of evidence and legal protections making it clear that it is extremely detrimental to their survival.” [18]

On the Vattenfall proposal to extend its wind farm by felling a quarter of the forest, the letter says that “FES were keen to keep this ‘under the radar’ according to their internal emails, expecting wildcats would be an issue; which we find outstandingly poor behaviour for a public agency, managing a public forest, talking about a legally protected and critically endangered species.” The letter also criticises Scottish Natural Heritage for its spending £2m on “allegedly saving the wildcat” while dropping its own population estimates from 400 to 100 over the same period. The letter concludes:

“We, and over 200,000 other people, believe the case is clear: the wildcat is not safe so long as Clashindarroch can be commercially exploited. Scotland has many windy hills and many commercial forests, but this is the only one with a resident population of wildcats… We feel the only sensible choice is to put a moratorium on all forest exploitation in Clashindarroch Forest until Parliament is next in session and able to deliver a fully informed decision on whether it can be protected.”

Steve Piper said that he had also written personally to Scotland’s First Minister, requesting a stop to all logging activities in the forest, and pointing out “that the actions of the Forestry Commission there are very much illegal.” Wildcat Haven had also written separately to the Forestry Commission, he said, “outlining the same legal complaint and making it clear that any further logging will be reported to the police as a wildlife crime.” By August 8th, the petition had reached 300,000 signatures, but neither Scotland’s First Minister nor the Forestry Commission had responded to the concerns expressed in the letters.

Habitat Destruction – The Rail Network

Large-scale tree felling became the subject of a fourth petition on, started by Ray Walton in response to a massive clearance operation by Network Rail [19]. The UK’s rail network consists of about 10,000 miles of track, and the 20,000 miles of trees and vegetation on either side provide significant corridors for wildlife, second only to the road network in terms of scale [20]. The seasonal problem of fallen leaves is well-known to rail passengers, and Network Rail has always had a policy of clearing trees and vegetation growing close to the track, and any foliage that is deemed to pose a risk to train and passenger safety.

However, on the 29th April, the Guardian published an exclusive by environment correspondent Sandra Laville, which disclosed that millions of trees were at risk in a secretive Network Rail felling programme [21]. She reported that the company “has created an aerial map of its 40,000 hectares of railway and identified ‘hotspots’ where mature trees might cause a problem at an unspecified time in the future.” Network Rail’s head of media Kevin Groves denied that the programme was secretive, saying that information on its tree-felling programme was freely available on its website, and that its tree census had enabled the company’s operations to be more targeted, “eliminating needless clearance work and enabling us to be more efficient and better at managing the line-side.” He is reported to have said that “biodiversity matters to us,” but Sandra Laville says that its engineers “are operating in a targeted felling programme that dwarfs the operation by Sheffield City Council that was paused in the face of huge public protest and condemnation from the environment secretary, Michael Gove.”

“Thousands of poplars, sycamores, limes, ash trees and horse chestnuts have already been chopped down across the country from Yorkshire to Dorset, and the scale of the potential destruction outlined in a Network Rail blueprint involves 10m trees growing within 60 metres of track… Over the last fortnight, people around the country have woken to the sound of chainsaws and expressed concern at the lack of consultation and the scale of the destruction. In one incident, police in Bournemouth were called by residents to complain that engineers were operating illegally as the felling is taking place during the nesting season. At one west London station this week, an engineer felling five mature trees said they were carrying out a ‘pre-emptive strike’ in case branches or leaves fell on the line in future… In Sutton Coldfield, teams working for Network Rail have been felling hundreds of track-side trees…”

The eye-witness accounts reported by the Guardian suggest that Network Rail’s idea of “targeting” is to select a length of the rail network for the mass obliteration of all trees and vegetation:

• “Ray Walton witnessed hundreds of trees being chopped down along the length of track between Christchurch and Bournemouth. ‘It was total mass destruction, they obliterated every tree,’ he said. ‘These trees were mature 30-foot-high trees which have been there for 50 years in some cases and never caused a problem. This went far beyond reasonable management of the trees. They took them all out, and destroyed the habitat for wildlife.'”
• “James Graham from Manchester said he saw thousands of trees being felled last week along a 10-mile section of the Trans-Pennine route from Manchester to Leeds. ‘I know they have to manage the trees, but this was excessive,’ he said. ‘It looked like some kind of logging operation. I was sitting in the train and looking out at the countryside and all you could see was mile after mile of tree stumps and sawdust. They had felled trees which were a long way from the track. It was extreme.'”

Network Rail’s “slash and burn” approach

Network Rail admitted to the Guardian that the vast majority of the trees being felled were healthy but defended the operation, saying that its new tree database of hotspot problem trees has “revolutionised” its approach to “vegetation management” and cut delays and risks to passengers from tree branches. Sandra Laville said that the timing of the operation has caused increased outrage because it is taking place during the nesting season, “despite promises by Network Rail that no felling would take place when birds are nesting.” Network Rail’s media head Kevin Groves said that those assurances about the nesting season do not hold true if trees constitute a risk, such as locations where train drivers are unable to see line-side signals.

However, the eye-witness accounts show that the operation is far more extensive. Caroline Lucas of the Green Party is reported to have said that the scale of the operation was shocking and an act of environmental vandalism. “While some tree work is required on safety grounds,” she said, “Network Rail’s approach tends to be one of slash and burn. To be taking action in the nesting season is even more reckless.” Friends of the Earth criticised the clearance of habitat as “insensitive,” while the RSPB said that Network Rail may well be in breach of the legislation that protects nesting birds.

“Enhanced Clearance”

The Guardian published a further exclusive on the 9th of May, after receiving a leaked Network Rail document that “sets out a series of alternatives for dealing with the millions of trees along Britain’s railway over the next five years.” [22] According to the Guardian, Network Rail says it owns 6m trees and the internal document identifies 13m trees within falling distance of the tracks, “some on third-party land and some on its own land.” Sandra Laville reports that Network Rail’s preferred option is a programme of “enhanced clearance”:

“Entitled Lineside Asset Management Control Period 6 (CP6), the document’s preferred option involves the “removal of all leaf fall species” within falling distance of the track, “intensive intervention” on vegetation in close proximity to the railway, and the removal of emergent lower level growth at the earliest stage. The area for management of scrub, grasses, trees and shrubs will also increase from five metres either side of the railway – which has been the policy for the last five years – to a minimum of 6.5m. Grasses and scrub alongside Britain’s railway lines are made up of more than 1,600 species of plants, including 900 varieties known as ‘railway species’ that are exclusive to the track-side.”

Network Rail said that the preferred option has not been adopted as policy and denied that the document is a statement of intention. In an email to the Guardian, it said: “It is a piece of modelling work our regulator asked us to do that actually demonstrates that moving to a more aggressive vegetation approach is very costly and does not represent value for money.” According to the Guardian, the document specifies that it would need £41,000 per mile of track for the enhanced clearance and states that this would result in “a far better performing safer railway.” However, “if the estimate is extrapolated across the entire 20,000-mile network, it would cost more than £800m.”

Network Rail’s CEO summoned for talks

Sandra Laville says that the 2019-24 policy document emerged as Environment Secretary Michael Gove summoned Network Rail’s CEO Mark Carne for talks over its approach to environmental management following her revelations about nationwide tree felling. As a result of those talks, Transport Minister Jo Johnson set up a review into Network Rail’s vegetation management and called for all tree felling to be suspended during the current nesting season of March to August [23].

She also says that some facts have emerged following the submission of a Freedom of Information request to Network Rail. Network Rail said in its response that it cuts down about 50,000 trees a year, and that 30,000 trees were felled on the west coast mainline between Euston and Carlisle in the twelve months between February 2016 and February 2017. Network Rail said there were no plans to replace any of the trees. The Guardian also reports that Network Rail has not responded to requests to provide an aerial map highlighting “problem” trees earmarked for felling.

On a positive note, a further article by Sandra Laville revealed that Bromley Council in Greater London had issued Tree Preservation Orders to prevent Network Rail from felling any track-side tree within its boundary [24]. This means that Network Rail will now have to seek permission from the council before it can fell a tree and will have to provide reasons for the removal. In June, however, Ray Walton reported that Network Rail was still removing trees in parts of the country, despite the Government’s call for a temporary suspension [25].

Corporate Interests and Conspiracy Theories

Ray Walton also suggested that Network Rail had ulterior motives for the mass slaughter of healthy trees. Since the start of his petition, he said, two reasons had come to light as to why this was taking place nationwide. First, he hinted at the links between Stobart Rail, one of Network Rail’s contractors, and Stobart Energy, who supply wood for biomass power stations:

“At least one of Network Rail’s tree and vegetation management contractors has a contract to supply wood to be burned in biomass power stations around the UK The contractor’s sister company manages around 2 million tonnes of arboriculture and forest residues per annum. They have a huge appetite for material nationally, and collect the material and process it into saleable fuel, which is supplied to the renewable energy sector. This in-house connection allows the company to offer significant savings back to Network Rail as it can harvest, extract, and sell material that would usually be chipped to waste.”

Ray Walton voices the opinion that “they” (unspecified, but presumably he means Stobart) “are looking to destroy all our healthy UK trees for this purpose, and are on the prowl for new sources of healthy trees and forests to exploit, mass fell and burn for profit, to sustain their profiteering biomass wood burning interests in the UK, using what they call the ‘De-vegetation Framework’.” The company claims that the framework provides a sustainable source of fuel, he says, because new saplings are planted in place of the felled trees, but not on land owned by Network Rail.

The claim that a Network Rail contractor is “looking to destroy all our healthy UK trees to support its profiteering wood-burning interests” does sound like a conspiracy theory, but the relationship between Network Rail and its contractors does need, as Ray Walton suggests, “serious scrutiny and investigation.” For instance, why has Network Rail’s contractors persisted in a programme of mass destruction when the Government has ordered a pause? Does Network Rail monitor the work being undertaken on its behalf? If so, is the monitoring adequate in reducing the risk of a contractor “going rogue”? [26]

The second reason is the new 5G mobile phone network:

“Network Rail is ‘preparing’ to receive and introduce the new 5G ‘microwave’ phone signal in 2020 to its clientèle on the trains and along the rail system. However, leafed tree and foliage along the sides and embankments ‘block the signal’ and hence ‘it won’t work’ as good as the older 3G and 4G signals already in place. Hence another relevant but omitted reason for felling all the trees along the railway lines. There seems to be a corporate profiteering tree-felling conveyor belt operation here and it can only get worse –unless we expose and stop it.”

Whether there is any substance to Ray Walton’s claims [27], the scale of the devastation is apparent. A nationwide wildlife corridor spanning 10,000 miles has received significant damage because of Network Rail’s clearance programme. And despite its claims to support biodiversity, its actions have done nothing to prevent the decline in the UK’s wildlife. [28]


Photograph: Little Glenshee to Strathbraan road, 3km from Milton, Perth And Kinross. © Copyright Richard Webb and licensed for reuse under this Creative Commons Licence. Scottish Natural Heritage has issued a licence to cull ravens in Strathbraan, ostensibly to investigate possible correlations between raven numbers and wader productivity in the breeding season. The RSPB has expressed outrage at the decision, pointing out that the area is managed for grouse shooting and is a notorious “black hole” for raptors, where birds of prey, including eagles and hen harriers, have disappeared under suspicious circumstances. The RSPB says that estates in this and other grouse shooting areas have been complaining “loudly” about raven predation of red grouse: “We and many others see this raven research proposal as simply a rather transparent mechanism whereby a perceived pest species can be removed to benefit red grouse, with the conservation of wading birds as a by-product.” [29]


[1] See the ENA article: “UK Government publishes its 25 year plan for the environment”.

[2] See the ENA article: “The future for farming: UK Government publishes proposals for a post-Brexit agricultural policy”.

[3] See the ENA article: “New rules for farmers ‘will help to protect the water environment'”.

[4] Alison Lowther’s petition, “Stop the proposed raven cull by Scottish Natural Heritage,” can be found on the website.

[5] See the article, “Concern over Raven research licence – RSPB Scotland’s response,” on the RSPB website.

[6] See the article, “Raven research licence: an update,” on the RSPB website.

[7] See BBC News, 30 July 2018, “Raven cull licence suspended for being ‘not scientifically robust’,” at

[8] See the article, “Response to licences granted by Scottish Natural Heritage,” on the RSPB website.

[9] See BBC News, 8 March 2018, “Nine areas of England apply to join badger cull,” at

[10] The news was reported in the Telegraph on 27th May 2018, in an article titled “Farmers to be offered £50 a kill as badger cull is rolled out across most of England.”

[11] See [9].

[12] Lee Jenkins’ petition, “Stop the nationwide cull of Badgers,” can be found on the website.

[13] Lee Jenkins cites the article, “Controversial badger cull to stamp out TB could be extended,” published by the Daily Mail on 16th February 2018.

[14] See the Wildlife Trusts website at

[15] Steve Piper’s petition, “Save the Scottish wildcat by protecting Clashindarroch Forest,” can be found on the website.

[16] See the Wildcat Haven website.

[17] The plans are revealed in a scoping report, published as a PDF document on the Vattenfall website, and discussed by Steve Piper in a petition update on 21st June 2018. News of the proposed wind farm was reported in an article in The National, which headlined with the claim that almost a third of Scotland’s wildcat population could be wiped out by the development.

[18] The basis for citing a figure of 90 hectares is unclear. Presumably however, as Clashindarroch Forest is a commercial forest, the size of a felled area must meet a certain standard of commercial viability. Scottish Wildcat Action, which works in partnership with Forest Enterprise on the conservation of wildcats in Clashindarroch Forest, has responded to these criticisms by saying that in any one year around 1.5% of the total forest area is thinned or felled. This area is “made up of relatively small patches in relation to the home range of the wildcats living there.” They argue that grasses start growing when the timber crop is removed, and that this provides ideal habitat for voles, an important food item for the wildcats. They cite research on wildcat conservation elsewhere in Europe, which shows that “wildcats prefer habitat mosaics of open ground and closed cover.” For the full response, see the Scottish Wildcat Action website.

[19] Ray Walton’s petition, “Stop Network Rail Chopping Down Millions of Trees!”, can be found on the website.

[20] The precise length is reported in documents published by the Office of Rail and Road and summarised on a Wikipedia page.

[21] Sandra Laville, “Millions of trees at risk in secretive Network Rail felling programme,” published by the Guardian, 29th April 2018.

[22] Sandra Laville, “Revealed: Network Rail draws up option to remove all ‘leaf fall’ trees from wider trackside area,” published by the Guardian, 9th May 2018.

[23] In a GOV.UK news story published on the 10th of May, Jo Johnson said that “the review will look at whether Network Rail has the capacity and capability to manage vegetation in a way that minimises harm to wildlife.” The review was expected to report its findings in the summer.

[24] Sandra Laville, “Local council issues tree preservation orders to stop Network Rail felling,” published by the Guardian, 11th May 2018.

[25] See the petition update on Ray Walton cites the example of Newbury in West Berkshire, where tree felling was still continuing on a large-scale despite the call for a temporary suspension. In an article for the Newbury Weekly News, Fiona Thomas reports that the work was expected to continue through the summer, and provides a number of eye-witness accounts of the scale of the destruction.

[26] In a petition update , Ray Walton provides a number of links to justify his claims. For instance, Stobart Rail claims to be Network Rail’s “vegetation management specialist,” while Stobart Energy claims to be “the UK’s number one supplier of biomass fuel.” An article in the energyst reported in March that Stobart was “on track” to deliver 2m tonnes of biomass per annum, presumably as a result of its work on Network Rail’s clearance programme.

[27] On Network Rail and the new mobile phone network, Ray Walton cites a government press release, which announced at the end of 2017 that “ministers are now looking at ‘future proofing’ rail connectivity to help pave the way for a 5G rollout.”

[28] See the ENA article on The State of Nature 2016, a report that examines the causes of wildlife decline in the UK. See also the ENA article on the UK’s bird populations. For the significance of wildlife corridors, see the ENA article on the Wildlife Trusts’ vision of a “Wilder Britain”.

[29] See [5].


Environment Agency “invested £1.3bn on the environment in 2017-18”

Flood and Coastal Erosion Risk Management accounts for almost two-thirds of EA spending

Annual Report measures Environment Agency performance

July 25th 2018

The Environment Agency published its annual report this month, together with its financial accounts for the 2017-18 financial year. [1] The annual report reveals that the Environment Agency’s total expenditure for the financial year ending 31 March 2018 was £1,315.2m, roughly the same as the previous year’s expenditure. Defra funding accounts for 65% of this total expenditure, with 35% coming largely from fees and charges. Breaking down the expenditure by business area, the figures show that the Agency spent £826.5m of the £1.3bn total on Flood and Coastal Erosion Risk Management (known as FCERM), whilst the remainder (£488.7m) is attributed to “environment and business.” The latter includes a multitude of activities such as regulation of industry (environmental permits, licensing, enforcement and so on), monitoring (including water quality), investigations under the Water Framework Directive, and incident management. Over a third of the FCERM spending falls into the category of capital expenditure associated with flood and coastal erosion risk management (£298.1m).

The Environment Agency is a non-departmental public body which was created under the 1995 Environment Act. Under Section 45 of the 1995 Act, the Agency is legally obliged to prepare a statement of accounts for each financial year in the form set out by a direction from the Secretary of State for the Environment, Food & Rural Affairs. Although the Agency is independent of the Government, it carries out functions on behalf of Defra, its sponsoring department, and helps to develop Defra’s strategic objectives. Defra monitors the Agency’s performance and oversees the environmental policy that determines its operational framework. The Environment Agency is consequently the leading public body for protecting and improving the environment in England.

“Creating a better place for people and wildlife”

The Agency describes its vision as “the creation of a better place for people and wildlife,” and its three main areas of activity as flood and coastal erosion risk management; water, land and biodiversity; and regulation of industry. The Agency employs around 10,000 full-time staff and works with government, local councils, businesses, local communities, and groups such as the Rivers Trust. Local offices work closely with local communities to improve the environment and encourage sustainable development.

The Agency is currently working to achieve the goals set out in an Action Plan, titled Creating a better place: our ambition to 2020, and defines those objectives as: a cleaner, healthier environment which benefits people and the economy; a nation better protected against natural threats and hazards with strong response and recovery capabilities; and higher visibility, stronger partnerships, and local choices. [2] The Agency says three principles inform all of its choices: putting people and wildlife first (in line with its vision of creating a better place for people and wildlife); 80/20: “focusing on the 20% of things that make 80% of the difference;” and supporting local priorities, recognising that “every place and community has its own needs.”

New challenges

The Agency says that its Action Plan recognises the challenges of budget pressures, more extreme weather, and a growing population, and that these challenges require the Agency to innovate, “focus on the things which make the biggest difference,” and work more closely with its partners. The Agency’s CEO Sir James Bevan says in the annual report that the purpose of the Agency has not changed since it was first established in 1996: namely, to protect and enhance the environment and promote sustainable development. However, he continues:

“But the context in which we operate has changed dramatically. Climate change, the single biggest factor affecting our environment, is now better understood and starting to bite. Our country is more developed and more populous, putting greater pressure on the natural world. There is greater public awareness of the environment, and higher public expectation of us and the rest of the public sector. The 2016 referendum has brought a new challenge: to ensure that the UK’s exit from the European Union delivers a cleaner and greener country and a better environment.”

The CEO says that the Environment Agency was closely involved in shaping the Government’s 25 year Environment Plan, and delivering the plan is now one of the Agency’s main responsibilities. [3]

The latest challenge: Defra transformation “continues to pose risks and opportunities”

The annual report reveals that the Agency’s CEO and its Chair, Emma Howard Boyd, meet regularly with the Secretary of State and other Defra ministers. The topics discussed in those ministerial meetings have included the 25 Year Environment Plan; flood risk management and related issues; the future management of navigation waterways; illegal waste and the targeting of major problem sites; the UK’s anticipated departure from the EU; and supporting economic growth through prompt responses to planning enquiries and permissions for shale gas exploration and large infrastructure projects; specifically, HS2, Hinckley Point nuclear power station, Crossrail, and the Thames Tideway Tunnel.

Another major topic of those discussions has been the transformation of Defra, which has meant changes to the Agency’s structure. The annual report reveals that in the last financial year, the Environment Agency transferred the responsibility for most of its corporate services functions to Defra. This involved the permanent transfer of around 1,000 staff to Defra under the Transfer of Undertakings (Protection of Employment) Regulations 2016. The transfer is “part of a wider Defra group transformation programme initiated in response to Defra’s spending review settlement for 2015 to 2020.” The annual report says that the transfer, which took place on 1st November 2017, presented logistical and procedural challenges, requiring significant preparatory work to make the transition successful, and to ensure that “the Environment Agency continues to receive the services it requires to effectively discharge its responsibilities, operational requirements, and statutory duties, including as a Category One responder to incidents.”

The report says that one consequence of the transfer is that “some risks to the Environment Agency are now managed on our behalf by Defra. This has required us to develop new relationships between those who own risks on behalf of the Environment Agency and those who are managing them.” In a governance statement, the report says:

“The scale of the Defra group transformation continues to pose a variety of risks and opportunities for our day-to-day business. These include: failing to realise financial and non-financial benefits; not managing our people’s capacity for change and thereby adversely affecting morale; and not pacing change to ensure we maximise opportunities to learn and work better together with more consistent shared systems and processes. We continue to oversee the planning, scheduling, and delivery of change to manage risks and dependencies, maximise opportunities, and ensure that employees and employee relations groups are engaged appropriately… A partnership agreement between Defra and the Environment Agency has been established to guide working relationships and the delivery of services post-transfer… As plans are developed for transforming Defra Corporate Services to reduce expenditure and improve efficiency, the Environment Agency will be consulted and these agreements will allow the services to be monitored and ensure that any negative impacts are minimised.”

The governance statement says that the transformation “may also affect transferred staff and increase turnover.” The Agency says it is working with colleagues in Defra “to mitigate any potential loss of corporate knowledge, effectiveness and efficiency,” including the possible re-employment of staff to continue doing corporate services work in the Agency. In particular, it wants to ensure that the staff who have been transferred “continue to feel part of the ‘Environment Agency team.'” The statement says that similar messages from the leadership of Defra Corporate Services are emphasising the importance of transferred staff continuing to prioritise Environment Agency activity as well as activity for the Defra group.

The Agency completes the transition to Open Data

The Agency says that during the 2017-18 financial year, it completed its plan to remove all charges for the commercial re-use of Environment Agency data. This means that since April 2018 users have been able to use the Agency’s data for free with minimal licence restrictions. The annual report states:

“The removal of charges is part of the Open Data commitment we made in 2014 to publish more freely available data. Since 2015 we have progressively removed charges from almost 100 datasets including LIDAR (Light Detection and Ranging). LIDAR provides high resolution maps of data that can be used for a variety of purposes such as geo-spatial environmental management. Our datasets have been downloaded over a million times since being published. We have seen free of charge data benefit communities, for example by the Pang Valley Flood Forum and by the Red Cross in its emergency mobile telephone application alerting users to localised emergencies. We also witnessed surprising uses of our open data, for example archaeologists using our LIDAR data to find lost Roman roads.”

The Agency’s commitment to make more data freely available for public use was reported in our news story towards the end of 2014, “Environment Agency’s Open Data Initiative will make more data freely available for public use”.

“A cleaner, healthier environment”

In her foreword to the annual report, the Chair of the Environment Agency Emma Howard Boyd says that the Government’s 25 year Environment Plan pledges to deliver the United Nation’s Sustainable Development Goals, “and to make sure all policies, programmes and investment decisions take into account the possible extent of climate change this century.” She says that the Environment Agency is already moving towards many of the UN’s goals. In particular, Goal 6, Clean Water and Sanitation, is reflected in the Agency’s work on enhancing watercourses and reducing pollution; Goal 11, Sustainable Cities and Communities, is reflected in the Agency’s work on flood protection; and Goal 15, Life on Land, is reflected in the Agency’s work on habitat creation.

The Environment Agency’s current Action Plan includes performance criteria that measure the Agency’s success in achieving those goals. The annual report describes five categories of performance measures, which include four measures for a cleaner, healthier environment, and three measures for a nation better protected against floods. Under the category of “a cleaner, healthier environment, benefiting people and the economy,” the Agency lists the following four measures of success:

1 “The water environment is healthier.”
2 “We protect people, the environment and wildlife by reducing serious pollution incidents.”
3 “We create new habitats.”
4 “We reduce the number of high-risk illegal waste sites.”

On the water environment, the Agency had a target of enhancing 1,500km of England’s watercourses in 2017-18 and succeeded in exceeding the target by enhancing 2,038km. The Agency says this includes work done with and by catchment partners and other stakeholders. The work has been concentrated on locations identified for improvement in updated River Basin Management Plans, which set out measures to restore and enhance river habitats. The annual report says that the Agency has been working with partners in improving water quality and biodiversity through a range of work programmes, including advice to farmers and landowners on a range of issues; for instance, the reduction of pollution run-off into waterways through the countryside stewardship and other schemes. The Agency has also been working to reduce the impact of invasive species, “such as floating pennywort and Himalayan balsam on the Upper Witham River in Lincolnshire.” The Agency says this work has prevented deterioration and maintained the quality of the water environment, whilst “improvements by water companies have reduced pollution in many catchments across the country.” The Agency has set another challenging target for 2018-19 of enhancing 2,000km of watercourses, in order to move towards the goal of enhancing at least 8,000km by 2021.

On pollution, the Agency reports that the number of serious and significant pollution incidents (known as Category 1 and Category 2 incidents) in 2017-2018 fell to 402 from 477 in 2016-17, which represent its lowest pollution levels since 2011. The fall was achieved “by targeting sectors showing the poorest performance for pollution incidents, and using this information to prioritise where to allocate our resources. We then used pollution incident reduction plans to manage the primary causes of pollution for individual pollution sectors.” The top three regulatory sectors, which accounted for 40% of all Category 1 and 2 incidents in 2017-18, were water companies, illegal waste sites, and agriculture, but the total number of pollution incidents for the top three sectors saw a 28% reduction when compared to the previous year. The Agency says that this “top sector approach” has reduced incident numbers in all of the prioritised sectors apart from agriculture, which saw a 13% increase in pollution incidents in 2017-2018. To address the issue of agricultural pollution, the Agency has been working with Defra on a set of new rules for farmers, which came into force in April. [4]

The challenge of plastic pollution

The annual report also includes a special mention of plastic pollution. The Agency says that “plastics in our rivers and oceans has been described as the greatest environmental challenge of our time.” Following Sir David Attenborough’s highlighting of the issue in the BBC’s Blue Planet series, the Agency has established a team to focus on reducing plastic pollution and improving sustainability as part of the Government’s 25 year Environment Plan. The Agency says that plastic pollution is a threat to our natural environment which cannot be tackled in isolation. By working together, however, “we can reduce the amount which enters our land, rivers and the sea, and protect wildlife for future generations.” The team will bring together charities, community groups, academics, and representatives from industry and water companies, and will work on the issue holistically. The areas of work will include: reducing plastics reaching land, waterways and shorelines; promoting better environmental practices in business and a reduction in plastic waste from the start of the manufacturing process; increasing local engagement to change public behaviour and encourage more community action to tackle pollution; and monitoring and research into the ways plastics enter and affect the environment.

Habitat creation

The third performance measure in the “cleaner, healthier environment” category is the creation of habitats. The Agency reports that it exceeded its target of creating 530 hectares of new priority habitats in 2017-18 by delivering 619 hectares. It defines priority habitats as “those most threatened, and requiring conservation action under the UK Post-2010 Biodiversity Framework.” As well as river restoration and maintenance projects, the work of habitat creation is also an integral part of flood risk management projects (see ‘Natural Flood Management’ below). The Agency says that “habitat creation projects reduce soil erosion and provide recreation and climate change adaptation in addition to their primary role.” One such project is the Pennine Peat Partnership, involving work with water companies to reduce downstream flood risk by slowing the flow, whilst also filtering the water which reduces the amount of chemical treatment needed for the water companies. The project has created 125 hectares of blanket bog, which will help to increase biodiversity and to store carbon to mitigate the impacts of climate change.

Illegal waste sites

The fourth performance measure in the “cleaner, healthier environment” category is the number of high-risk illegal waste sites. On this measure, the annual report reveals that the Agency failed to meet its targets. The report states:

“It remains a priority to reduce the impact of waste crime on local communities and ensure a level playing field for legitimate businesses. However, in spite of our efforts we have been finding more illegal waste sites than we are able to close down. The total active high-risk illegal waste sites rose slightly to 259, up from 253 in 2016-17. Whilst we have not hit our target for this year, we stopped a large number of waste sites from operating and we have a good prosecution record. In 2017-18 we made 93 successful waste crime prosecutions resulting in 17 prison sentences. Total fines were in excess of £380k, with some of the highest fines for individuals being issued. To ensure we hit our target for next year, we have been given new powers to help enforce against illegal waste activity and further reviews of legislation are anticipated. The Government has also provided more funding to tackle this serious problem and we shall continue to work with the legitimate waste industry and with other enforcement bodies, particularly HMRC, to tackle the problem.”

More details of the Government’s response to waste crime are given in the governance statement. The report says that a consultation has been carried out on proposals to raise the barriers of entry to the waste permitting system and to reform the exemption system. As well as new regulations that give the Agency stronger powers of enforcement, the Government announced additional funding of £30m to tackle waste crime in its November 2017 budget, “which extends current funding for two years beyond April 2020 and adds an additional £5m for each of the four years starting April 2018.”

In her foreword to the annual report, EA Chair Emma Howard Boyd says: “Unfortunately, environmental crime persists despite the work of the courts implementing the sentencing guidelines. We closed 57 high risk illegal waste sites in the first three months of 2018 and in March we were given new powers to lock up sites and force rogue operators to clean up all waste. I have publicly called for higher fines for pollution incidents and stronger sentences as a greater deterrent to waste crime.”

Capital spending on flood protection

The second category of performance measures concerns flood protection. First, we look at the Environment Agency’s spending on flood and coastal erosion risk management, as revealed by the figures in the annual report. The Agency says that the Government has made a long-term financial commitment to flood protection via the Agency’s six-year capital programme, designed to reduce the likelihood and the impact of major flooding. Also, the Agency was allocated an additional £76m of funding in the 2017 autumn budget, “of which £36m is for bringing new schemes into the capital programme and £40m is for flood defence schemes that help support economic regeneration in deprived communities.” The accounts reveal where the funding for flood protection has been spent in 2017-18. As regards capital expenditure, the Agency spent a total of £298.1m on capital works in 2017-18, compared to £291.4m in 2016-2017. The accounts list nine types of capital works, and the expenditure breaks down as follows, with the figures in brackets indicating the 2016-17 spend:

• £9.2m [£11.3m] on beach replenishment, which involves “sand and shingle replacement on beaches to retain the integrity of a coastal defence.”
• £14.7m [£19.4m] on culverts and channel improvements, involving “work on repairing or replacing culverts under land, roads and properties, and channel improvements that assist the flow of watercourses.”
• £44.6m £[43.5m] on embankments (“the creation, improvement, or heightening of embankments to reduce the risk of water escaping from a river channel”).
• £35.3m [£39.7m] on the Agency’s flood risk management strategy (“long-term flood risk management options for fluvial catchments out of which individual flood risk projects are developed”).
• £3.8m [£4.3m] on flood mapping (“the production of multi-layered maps which provide information on flooding from groundwater, rivers and the sea. Flood maps also have information on flood risk management assets and the areas benefiting from those assets.”)
• £2.6m [£2.5m] on piling: “This relates to the installation of piles (normally steel) along riverbanks to strengthen them and secure the adjacent land, and prevent landslips into the river causing obstructions. These works are largely below ground.”
• £157.5m [£130.1m] on restoration and refurbishment: “This involves carrying out works to ensure that flood risk management assets are in the appropriate condition and restored to that condition.”
• £2.3m [£1.9m] on rock groynes and sea walls: “Rock groynes and sea walls are built as part of sea and coastal flood risk management assets and are often used in conjunction with beach replenishment activity to prevent sea flooding. The responsibility for maintenance often resides with the local council.”
• £28.1m [£38.7m] “other” (the details are not specified).

In addition, the Agency awarded £77.2m of capital grants to local authorities and Internal Drainage Boards, and £20.0m was spent on reservoir operating arrangements, with the largest payments payable to Northumbrian Water (in relation to Kielder reservoir) and Severn Trent Water (in relation to Lake Clywedog and Lake Vyrnwy reservoirs).

“A nation better protected against floods”

Returning to the Agency’s performance measures, there are three measures of success under the general category of flood protection:

1 “We reduce the risk of flooding for more households.”
2 “We maintain our flood and coastal risk management assets at or above the target condition.”
3 “We have a first class incident response capability,” as measured by a) the number of staff who are trained and ready to respond to incidents; and b) the percentage of staff who feel confident in the role.

On flood risk reduction, the Agency says it has completed a number of flood risk management projects in 2017-18, resulting in better protection for 45,864 homes. The Agency reports that 142,850 homes have now received better protection since the start of a six-year capital programme in April 2015, and it expects to achieve a six-year target of better protection for 300,000 households by March 2021. Some “notable examples” of completed projects include the Anchorsholme coast protection scheme, which has reduced flood risk to 4,800 properties in Blackpool and also provided “increased protection to vital infrastructure and safeguarded Blackpool’s iconic seafront tramway.” [5] A second example is the Salford flood alleviation scheme, which “has seen the development of a flood basin and reduced flood risk for 1,400 homes, as well as providing a recreation area with a nature reserve.” A third example is the Sheffield Lower Don Valley scheme, which is “the first in the UK to have business owners contributing to the costs of flood protection. It has led to the reduction of flood risk for around 500 businesses and 600 homes as well as helping to safeguard around 5,000 jobs. All of these projects were completed in partnership with the local authorities.”

The Agency’s Flood Warning Service

The annual report includes an update on the Agency’s flood warning service, which it says continues to grow, “sharing information with customers before flooding so that people have time to prepare and take action.”

“The flood warning service is now able to reach more people, in a shorter timeframe, in the event of severe weather. Improvements in technology have helped this and at the end of March 2018 over 1.4 million customers were registered for the service in England. We want to make those at risk of flooding more resilient, and to achieve this we have refreshed our five-year flood incident management plan. The Plan describes the activities carried out to help individuals and communities prepare, respond to, and recover from flooding. We have already made significant progress towards implementing the plan. By focusing on objectives to increase the quality and availability of information, our customers are better placed to understand the risks and respond to impending flooding.”

In a governance statement, the Agency says that 1.4 million people have now signed up to its flood warning service, an increase from 1.2 million in the previous year. The increase is attributed “largely to mobile phone companies coming on board with our Flood Warnings Direct service for their customers in flood risk areas and the impact of our 2017-18 Flood Action Campaign, ‘Prepare, Act, Survive,’ which informed people what they should do if they live in an area at risk of flooding.” The campaign resulted in 67,000 new registrations to Floodline Warnings Direct, over 32,000 visits to the Agency’s ‘Floods Destroy’ campaign website and an estimated social media reach of 4.6 million. The Agency says it is also continuing to work on “implementation of the National Flood Risk Review measures in partnership with other government agencies.”

Natural Flood Management

The annual report highlights the importance of natural flood management (NFM) in managing flood risk and coastal erosion. The report states that NFM “protects, restores, or emulates the natural function of floodplains and the coast. NFM can offer a wide range of benefits in addition to reducing flood risk and coastal erosion: it can create important wildlife habitats, improve the local environment, and create recreation opportunities.”

The Agency reports that, in July 2017, the Government announced funding for 60 projects in a £15m NFM programme. Four criteria were adopted to select the projects: firstly, the project would need to reduce flood and/or coastal erosion risk; secondly, it would improve habitats and increase biodiversity; thirdly, it would contribute to research and development, thereby reducing the evidence gap for NFM; and fourthly, it would promote partnership working. The Agency says that the programme started in the 2017-18 period and will continue until 2021, with monitoring arrangements put in place in order for a greater understanding of the flood risk and environmental benefits of the programme.

Further funding for NFM projects has been made available in the form of £3.4m of research funding allocated to the Natural Environment Research Council (NERC) for spending on research projects. The Agency says it collaborated with Defra in designing the call for research proposals. The funds have been awarded to three proposals: one on the Upper Thames, proposed by Reading University; a second in Cumbria, proposed by Lancaster University; and a third in the Peak District, proposed by Manchester University. The Agency says that the research will improve understanding of the effectiveness of different NFM measures for a range of flood risk scenarios.

In October 2017, the Environment Agency published the ‘Evidence base for working with natural processes to reduce flood risk,’ which compiles existing research into a directory for flood and coastal risk managers. The Agency says “this easily accessible directory will help to ensure that potential NFM measures can be assessed and used where they are effective.”

Flood risk management assets

The second performance measure in the flood risk category is asset management. The Agency reports that it achieved a national target “by maintaining 97.7% of flood risk management assets at the required condition for high consequence systems.” Flood risk management assets include embankments, storage areas, flood gates and sluices, whilst a high consequence system is defined as a group of flood risk management assets in a location where there would be significant impacts to people and property if the assets failed. The Agency says it increased the number of assets above the required condition by over 1,600 in 2017-18, which is a result of increased funding in asset management and “directly allocating this funding to where it has the greatest benefit, such as assets that are below the required condition.” Assets identified as being below the required condition indicate that work is required, but “does not mean that they have structurally failed or that their performance in a flood is compromised. If the performance of an asset is reduced, we will take action to ensure that flood risk is effectively managed until the asset is repaired or replaced.” The annual report states that the Agency has 40km of temporary flood barriers and 250 high-volume pumps available for deployment during flooding incidents: “these temporary measures work in tandem with the more permanent structures that have been or are under construction or may be used where more permanent measures are not practicable.”

Response capability

The third measure in the flood risk category is response capability. The annual report says that the Agency is continuing to embed a new incident response capability framework, following a ‘Major Incident Ready’ initiative in 2016. The measurement of its success is given by, firstly, the number of staff who are trained and ready to respond to incidents; and, secondly, the percentage of staff who feel confident in the role. The Agency reports that 6,568 staff are now trained and ready to respond to incidents, exceeding its target of 6,500. [6] Additionally, the Agency trained around 1,200 soldiers “before this winter to be able to support flood response if needed and joint exercises were undertaken.” The incident response staff includes 700 flood support officers, and the Agency says that “during the most severe storm this winter, Storm Brian, we protected 1,250 properties in Devon, Cornwall and the Isles of Scilly, through our actions and defences.”

However, in a sample of incident staff surveyed in 2017, only 69% felt confident responding to an incident, which failed to meet the Agency’s target of 80%. As a result, the Agency says it has taken steps to improve capability and confidence by introducing a new capability standard for incident staff to ensure they are fully trained and capable of responding. In addition, the Agency issued new guidance in November 2017 to clarify its role in responding to surface water flooding, groundwater flooding, and reservoir failures.

As well as flooding events, the Agency says that in 2017-18 it also responded to “serious chemical incidents, very large fish kills, animal disease outbreaks, major fires, and numerous other environmental incidents.” It is currently working with industry and water companies to reduce the number and severity of environmental incidents, and has set an ambitious incident reduction target for the current year “which will be the lowest in decades.” The Agency reports that it has also prepared for an approaching drought.

“Value for money” and responses to planning consultations

The annual report includes three other categories of performance measures. The first concerns “value for money” criteria, as measured by efficiency in financial management and by a prompt response to planning application consultations (i.e., within 21 days). On the efficiency measure, the Agency says “we report this measure by monitoring the percentage of our budget that we have invested,” on the assumption that expenditure is a proxy for the delivery of environmental outcomes. The Agency says the higher the percentage of budget invested, the more it can achieve for the environment. It reports that it invested £1.3bn on the environment in 2017-18, “with expenditure on both our grant-in-aid and charge-funded activities closely matching our available funding.” The result of regular reviews in the last financial year meant that the figure represents an investment of 99.8% of the Agency’s full-year budget.

On planning application consultations, the Agency says it responded to 95.4% of planning consultations within 21 days, exceeding its target which was set at 95%. The percentage represents a small drop of 0.2% from last year, but the Agency says “this is set against an increase in demand for our service and reduced resources.” Prompt responses have been helped by the Agency’s offering a pre-application advice service. This has meant that potential issues can be worked through with developers before planning applications are submitted, which reduces the amount of time needed for consultation at statutory stages. The Agency says that, at application stage, it prioritises commenting on planning proposals where the risks to the environment, or the opportunities for enhancement, are the greatest.

Other performance measures

A further category of performance measures is labelled somewhat vaguely as “an organisation continually striving to be the best, focused on outcomes and constantly challenging itself.” However, the measure of performance here is more concrete, which is a reduction in the Agency’s carbon footprint. In her foreword to the annual report, Environment Agency Chair associates this measure with Goal 13 of the United Nation’s Sustainable Development Goals, ‘Climate Action.’ “Making the country more resilient to storms, floods and droughts is our priority,” she writes, “but we are also involved in climate mitigation.” On this measure, the Agency reports that in 2017-18 it reduced its carbon footprint by 45% to 32,450 tonnes against a 2006-07 baseline year, compared to a target of 43%. The reduction was achieved through energy efficient measures such as boiler replacements, the closure of old buildings, and the gradual replacement of its fleet with low-carbon alternatives.

The final category of performance measures is mainly concerned with diversity in the workforce, as measured by the proportion of Agency staff who are from a black, Asian, or minority ethnic background, and by the proportion of its executive managers who are female. The Agency is currently not meeting its targets on either measure. On the former, the Agency says that because it has relatively low external recruitment levels, only 3.8% of its workforce are from minority backgrounds, set against the demanding target of 14%, “which reflects the minority proportion of the working population of England, rather than a lower one reflecting the mix of the Agency’s locations across England.” On the latter measure, the Agency says the proportion of its executive managers who are female has increased from 32% three years ago to 34%, but this is set against a target of 50%.

Overall, the Environment Agency has met or exceeded the majority of the targets it set itself for 2017-18. However, the development of plans mentioned above “for transforming Defra Corporate Services to reduce expenditure and improve efficiency” raises the spectre of departmental spending cuts in the drive for efficiency savings. The issues prompted by the Defra transformation, together with the Government’s preoccupation with an EU departure, all raise the question whether the next twelve months will be just as successful.


Photograph: The beach and promenade at South Shore, Blackpool. © Copyright Steve Daniels and licensed for reuse under this Creative Commons Licence. The Environment Agency has announced that the coastal protection scheme for the Anchorsholme area of Blackpool was completed in the 2017-18 financial year, one of a number of notable flood protection schemes to be completed in the last year. Blackpool Council first adopted a Coast Protection Strategy in 1995, and the Anchorsholme scheme represents the final stage of the strategy. The photograph was taken on Monday, 9th November 2009. See Note [5] below.


[1] The Environment Agency’s annual report is available as a PDF document from the GOV.UK website. Follow the link on the web page titled “Environment Agency annual report and accounts 2017 to 2018”. The annual report and accounts were published on the 12th of July 2018. For the corporate highlights, see the GOV.UK news story “The Environment Agency publishes Annual Report 2017 to 2018”.

[2] The Environment Agency’s Action Plan, developed in the 2014-15 financial year, includes more than 1,400 flood defence schemes. It came with the Chancellor’s announcement in the autumn of 2014 that £2.3 billion would be allocated to flood defences to be implemented over the next six years, in response to the increasing incidence of extreme weather and winter floods. See the ENA news story published on January 14th 2015, titled “Environment Agency looks forward”. Later that month, the Environment Agency warned that 7,000 homes will be lost to coastal erosion in the next 100 years. For more details of that, and news of some of the flood schemes announced by the Agency in 2015, use the search facility on this website using the term ‘Environment Agency’.

[3] On the 25 year plan, see the ENA article “UK Government publishes its 25 year plan for the environment”.

[4] On the new rules for farmers, see the ENA article “New rules for farmers ‘will help to protect the water environment'”.

[5] The coast protection scheme for the Anchorsholme area of Blackpool forms part of the Fylde Peninsula Coastal Programme, which also includes a flood protection scheme for the Rossall area of Fleetwood. See the ENA article published in October 2015, titled “Blackpool’s twenty-year coastal defence strategy nears completion”. The Environment Agency was expecting to complete the Anchorsholme project by the end of 2015 and the Rossall project by the end of 2017. However, work on the Anchorsholme project has been subject to a number of delays. In December 2014, BBC News reported that the foundation area for a new promenade had collapsed during the initial construction work by the contractors Balfour Beatty, though the contractors still expected to complete the work by the end of 2015. In July 2017, Blackpool Council reported that the work needed constant maintenance but was expected to be completed by the end of 2017. Finally, on the day of the official opening in October 2017, it became apparent that the sea defences needed further repairs owing to damage caused by recent storms, as reported by BBC News, but not in the news story on the contractors’ website.

[6] In a governance statement, the figure is given as “6,626 staff fully trained and ready to respond to flooding and other incidents, against a target of 6,500, including corporate services staff now employed by Defra,” which suggests that 58 incident staff are now employed by Defra.

New report describes The Wildlife Trusts’ vision of a Wilder Britain

The Wildlife Trusts call for the creation of a Nature Recovery Network

A Nature Recovery Network should be supported by a new Environment Act

June 13th 2018

The Wildlife Trusts have published a report for the Westminster Government “at a time when Britain stands on the brink of its biggest ever shake-up of environmental rules.” [1] As reported in previous articles, the Government has held two significant consultations in recent months – one on the future of farming policy following the UK’s anticipated departure from the EU, and one on changes to the National Planning Policy Framework. [2] In response to those consultations, The Wildlife Trusts launched their report at an event for MPs at Westminster. The report describes The Wildlife Trusts’ vision of a wilder Britain and how to achieve it. The vision includes the creation of a Nature Recovery Network, supported by legislation in the form of a new Environment Act. In a news story, The Wildlife Trusts said:

“The Wildlife Trusts’ new report shows how a Nature Recovery Network can be established by mapping out important places for wildlife which need to be protected as well as key areas where habitats should be restored. The Wildlife Trusts believe new laws are needed, including an Environment Act, to ensure this happens. Local Authorities should be required by law to produce local Nature Recovery Maps to achieve the new Government targets to increase the extent and quality of natural habitats, and turn nature’s recovery from an aspiration to a reality.” [3]

The news story goes on to say that The Wildlife Trusts’ report comes at a critical time for wildlife:

“It coincides with the final week of two key government consultations which present a rare opportunity – the first in living memory – to influence the future of both national farming and planning policy and how these impact on nature in England. Precious wild places and the species that depend on them have suffered steep declines over the past 70 years; intensive farming and urbanisation have been significant causes. Now the public has a chance to call for change, so that planning rules, farming support, and regulation work together towards the recovery of nature and wildlife. The Wildlife Trusts are urging people to respond to both consultations.”

Stephanie Hilbourne, Wildlife Trusts CEO, said substantial improvements were needed to farming and planning policies in order to help nature’s recovery, and an ambitious Environment Act was needed to put nature’s recovery on to a statutory footing.

Local Wildlife Sites and National Planning Policy

As mentioned in a previous article, the development of a ‘Nature Recovery Network’ is one of the Government’s aims in its 25 Year Plan for the Environment. [4] The Wildlife Trusts argue that to take this forward “Nature Recovery Maps should be at the foundation of future farming and planning policy, guiding habitat creation by farmers and housing developers to ensure it achieves government targets for wildlife’s recovery.” The news story also points out that policy protection for Local Wildlife Sites – “important havens for wildlife that are supposed to be recognised in planning policy” – has been dropped from the draft National Planning Policy Framework (NPPF). As reported in a previous article, the proposed changes to the NPPF focus on measures to boost house-building. [5] However, The Wildlife Trusts argue that dropping protection for Local Wildlife Sites is a backward step that would undo basic protection for 42,000 of these special places for wildlife. [6]

In their response to the consultation on the proposed changes, The Wildlife Trusts point out that about 36 square miles of land are used by new developments every year; hence “the outcome of this consultation is hugely important for wildlife.” The Wildlife Trusts want to see rules that protect wildlife and secure recognition of Local Wildlife Sites, which lose protection under the current proposals. Three further policy requirements are highlighted: firstly, planning policy should require wildlife habitats to be integrated into new developments; secondly, all developments should result in a ‘net biodiversity gain,’ meaning developers would be expected to make improvements for wild species and habitats; and thirdly, local planning strategies should require all new developments to contribute to a national Nature Recovery Network.

As for farming policy, the changes that The Wildlife Trusts would like to see here seem to coincide with the draft proposals set out by Defra. [7] The Wildlife Trusts say that they want to see rules that reward farmers and land managers for the benefits they provide for society, “like clean water, healthy soils and a wildlife-rich countryside.” Secondly, they want the Common Agricultural Policy replaced with a system that supports public benefits and environmental outcomes for society; and thirdly, they want to see changes to the culture of regulation, “making it easier for farmers to help nature without being weighed down by unnecessary paperwork, inspections and bureaucracy.”

Disconnected Nature

Moving on to the report, Towards a Wilder Britain begins by describing a vision of a “green, healthy, and happy” Britain in 2040, where “nature is normal.” The vision includes sketches of green developments, wilder cities, a buzzing countryside, sustainable fisheries, returning whales, fertile soils, and restored uplands. This is followed by a description of the “depleted, fragmented, and fragile” Britain of 2018, where 250,000 miles of road divide the landscape, creating a barrier for many species; plastics, pesticides, and atmospheric pollution are causing problems for wildlife; hedges in arable areas are disappearing; parks are “green deserts;” and people in urban areas live in artificial surroundings. In short, people have become disconnected from nature, and nature has become disconnected from itself.

As an example of the “nature disconnected” problem, the report cites Askham Bog, an ancient bog on the outskirts of York, cited as “a familiar story.” The report says that Askham Bog was one of The Wildlife Trusts’ first nature reserves: “It is a unique place, thousands of years old, and teeming with specialised wildlife, but it faces problems that are common to nature reserves all over the country. It is already bordered by a golf course, a landfill site, a major road, and railway. Now it is at risk of being sealed off completely from the landscape around it. Yorkshire Wildlife Trust has fought off two applications to build on its last remaining boundary.” The report also includes a map that shows estimates of ‘biodiversity intactness’ across the UK. The report says that the UK index of 81% is the 29th lowest out of 218 countries assessed by researchers, who suggest that such biodiversity loss ‘might exceed planetary boundaries.’

The report quotes Sir John Lawton, who led a Government review of England’s wildlife sites and ecological networks, titled Making Space for Nature. Published in 2010, the report said: “There is compelling evidence that Local Wildlife Sites are generally too small and too isolated. We need more space for nature.”

Reconnecting Nature – A Nature Recovery Network

The report also includes a quote from Sir David Attenborough, who said, “Every space in Britain must be used to help wildlife.” Pursuing the theme of “making space for nature to meet the needs of wildlife and people,” the report calls for the creation of a Nature Recovery Network, characterised as “a joined-up network of habitats that allow wildlife and people to thrive in housing estates; on farms; in nature reserves; on road verges; along riverbanks; in parks and gardens; on office roofs; and in the hills.” The report explains the need for such a network as follows:

“Nature conservation in the last century succeeded in protecting some vital wildlife sites, but wildlife has still declined as a result of damage to the wider environment. Protected wildlife sites alone cannot meet the needs of wildlife or society. To achieve that, we also need to provide effective protection for the many other places in the landscape that are still rich in wildlife despite the many pressures they face. And we must invest time, effort, commitment and money into bringing wildlife back across a far wider area, stitching back together Britain’s tattered natural fabric of wild land. We need to create a Nature Recovery Network that extends into every part of our towns, cities and countryside, bringing wildlife and the benefits of a healthy natural world into every part of life. Letting flowers bloom along road verges, installing green roofs across city skylines, planting more street trees to give people shady walks in the summer, encouraging whole communities to garden for wild plants and animals. A network that brings wildlife into every neighbourhood would also provide fairer access to nature for people. Studies have shown the benefits of living close to nature, but many people are deprived of these benefits.”

A Vision of a Wilder Britain

The report paints a picture of a wilder Britain which shows how space can be transformed in ways that benefit wildlife and people. For instance, the UK’s road network could be transformed by green bridges that allow wildlife a safe passage from one space to another. [8] The report says that green bridges should be a part of transport infrastructure projects, whilst road verges could be better managed for wildlife by mowing later in the year. Urban areas, home to 80% of the UK’s population, could be transformed by new parks, street trees and plants, green roofs and green walls, all of which would provide greener neighbourhoods, increase biodiversity, help to reduce flood risk, reduce overheating from concrete and tarmac, and thereby provide health and wellbeing benefits to people, who would be more able to experience nature in their daily lives.

On public spaces, the report says that two thirds of amenity land consists of short-mown grass, and that such spaces could support eight times more wildlife if they were transformed into wildflower meadows. On farmland, the report says that 70% of land in the UK consists of farmland, “so creating and managing habitats for wildlife on farms is vital: hedges, ponds, ditches, field margins and trees all help to provide a network of habitats for farmland wildlife.” The report also says that there are about 430,000 hectares of gardens in the UK, which have huge potential to help pollinators such as bees if more wildflowers were planted: “a network of small patches could help bees thrive in urban areas.”

Turning the Vision into a Reality

The vision of a wilder Britain becomes clearer with further details of the Nature Recovery Network, and the steps that are needed to achieve it. The report describes those details as follows:

“A Nature Recovery Network is a joined-up system of places important for wild plants and animals, on land and at sea. It allows plants, animals, seeds, nutrients and water to move from place to place and enables the natural world to adapt to change. It provides plants and animals with places to live, feed and breed. It creates the corridors and areas of habitat they need to move to in response to climate change. It connects wild places and it brings wildlife into our lives. It can only do this effectively if, like our road network, it is treated as a joined-up whole. The Network would include nature reserves and Local Wildlife Sites, and parts of National Parks. It would also contain peat bogs, heaths, meadows and cliffs; road verges, parks, gardens, hedges and woods; and rivers, streams, ponds and lakes. At sea, it would include reefs and sandbanks, rocky shores and sea-grass beds, many of them designated as Marine Protected Areas – Britain’s ‘Blue Belt’.”

The report describes four stages in creating such a network. The first stage involves greater protection for the wildest places, which include nature reserves, Sites of Special Scientific Interest, and Local Wildlife Sites (“our core sources of wildlife”). At sea they include Marine Protected Areas. The report says that these places need to be protected from harm, improved through better management, and where possible increased in size. The second stage involves making connections between those wild places through wildlife corridors: “Smaller patches of habitat can act as stepping stones and corridors between bigger areas. This means creating and looking after features like hedges, ponds, streams, small woods and meadows, to provide habitat and make it easier for wildlife to move through the landscape.” The third stage involves consolidating the overall area for wildlife by requiring land management and development to strengthen the network and not weaken it. The report says the overall area of wildlife-friendly land will increase by looking after our wildest places and creating the habitat corridors between them. This overall area needs to be safeguarded to ensure that wildlife populations are less likely to decline. The fourth stage involves finding space for wildlife in the wider landscape, “characterised by nature-friendly development and farming.” This stage would include encouraging a wide range of people to increase the amount of wildlife habitat in places like farms, parks, retail parks, churchyards, road verges, gardens and golf courses, and would need high standards of basic regulation.

Regulation: A New Environment Act

The need for regulation brings us to what The Wildlife Trusts describe as the most important requirement to achieve the vision of a wilder Britain: a new Environment Act. The report says that a new Environment Act “would commit successive future governments to increasing the diversity and abundance of our wildlife and making it a bigger part of everyone’s daily lives; and to improving the health of our air, soils, rivers and seas.” The report continues:

“This Act would build on the foundations of existing wildlife laws. It would be about nature’s recovery and rebuilding society’s connection to the natural world. It will need to ensure that regulation, investment, public spending and practical action work effectively together. To achieve this, it must place a duty on Local Authorities to produce Local Nature Recovery Maps, setting out where and how nature’s recovery will be achieved. And it must require government departments and agencies to use these maps to guide and coordinate their efforts.”

The report says that a new Environment Act will need ambitious goals; strong principles (to ensure that the needs of the natural world are central to all government decision-making and that polluters pay for their polluting activities); clear standards (including measures that set out how governments and other organisations will be held to account); and independent institutions to monitor and review progress, oversee compliance with the law, and to ensure that everyone can challenge public decisions effectively when necessary.

Nature Recovery Maps

The report describes Nature Recovery Maps as a key tool in the regulatory process, and as a means of achieving a Nature Recovery Network:

“Building a Nature Recovery Network requires detailed information: where wildlife is abundant or scarce; where it should be in future; which places are most important; and where there is opportunity for positive change. The critical tool is a Local Nature Recovery Map. Government must require Local Authorities to publish these maps, which would identify areas where the greatest benefit for wildlife and people can be achieved. They would focus and coordinate effective action, funding and regulation.”

The report says that these Nature Recovery Maps should be developed locally with the full involvement of civil society and other stakeholders; evidence-based using the best available data and technology; long-term but reviewed regularly; part of a national network aligned with neighbouring Nature Recovery Maps to create a national Nature Recovery Network; and endorsed by statutory documents approved by the Secretary of State.

The maps would be used to ensure that key wildlife sites are strongly protected as the basis for nature’s recovery (“critically, Sites of Special Scientific Interest and Local Wildlife Sites”) and that other sites are protected for future restoration. Local Nature Recovery Maps would also be used to ensure effective regulation of potentially damaging land management activities such as hedgerow removal or ploughing permanent pasture; and to ensure that new housing, industrial, commercial, and infrastructure developments receive consent only in the right places and has a net positive impact on the Network. Legislation would require local authorities to contribute to the implementation of the Network, and public and private funds should be channelled so that contributions from developers, for instance, are targeted for maximum wildlife benefit.

The report says that farmers, foresters, land managers, developers, investors, public bodies and regulators all have a role to play in making the Network happen. As for the rest of us: “All of us can help by taking action for, and providing space for, wildlife where we live and work. On their own our actions can feel isolated or small, but linked together every garden, window box, field margin, street tree and riverbank makes a difference.”

The Aire Valley: A Case Study of “Public Money for Public Goods”

The report includes examples of four pioneer projects that demonstrate, each in their own way, how a Nature Recovery Network could be achieved in practice. The first is a case study of the Aire Valley in Yorkshire. This long-term study, carried out by the Yorkshire Wildlife Trust, looked at alternative ways of spending farm subsidies, using the “public money for public goods” model which has been taken up by Defra in its proposals for the future of farming. [9] The Trust carried out research using three upland farms in Yorkshire as case studies to show how current farm incomes would be maintained or increased. The report explains the background to the study:

“A long, thin river catchment, the Aire starts in the Yorkshire Dales, running through the heart of Leeds and out to the Humber estuary. Although it has some very high quality habitats, much of the catchment is now too wildlife-poor and fragmented to prevent local species extinctions. Changes of land use in the Aire catchment have made flooding more likely. The Aire also suffers from pollution, mainly urban and agricultural run-off, particularly in failing parts of the river identified by the Environment Agency.”

Yorkshire Wildlife Trust used data from a range of sources to model how current farm payments could be applied differently to achieve environmental outcomes. The datasets were used to create a series of ecological maps of the Aire Catchment, which showed the location of current habitats, the location of potential habitats, and other features which included current payments to farmers and land managers, water quality, flood risk, and public access to the uplands. The study showed that under a new system of public money for public goods, a huge range of environmental and social benefits could be provided for the same amount of money paid to land managers and farmers at present. The benefits included improved access to the countryside; reduced carbon emissions; a significant reduction in flood risk for Leeds, Castleford, and other areas; and an increase in habitat for wildlife, including new broadleaved woodland and upland heath.

Pioneer Project: “The Wildlife Trusts work across land and sea”

The second pioneer project is a Regional Sea Plan for the Irish Sea, based on The Wildlife Trusts’ report The Way Back to Living Seas, which sets out proposals for a new UK Marine Strategy and was published in 2017. [10] The report says that with all sea users involved in its development, “the plan would guide how we develop marine industry, how we fish within environmental limits, and how we regain a sea full of wildlife.” The Wildlife Trusts explain that a national Marine Strategy provides an overarching plan, which is then made concrete in Regional Sea Plans and a nationwide network of Marine Protected Areas: “with these in place, national plans would give us the opportunity to manage our seas in a joined-up way.”

Pioneer Project: Lincolnshire’s verges

The third pioneer project is a six-year study by Lincolnshire Wildlife Trust of Lincolnshire’s road verges, which demonstrates the nature recovery potential of the 800 square miles or thereabouts of the verges bordering the UK’s roads. The report says that between 2009 and 2015 the Trust trained and coordinated volunteers to search 4,800 miles of the county’s verges for wildflowers. The information obtained as a result led to 159 new Local Wildlife Sites being designated, and better protection for 150 miles of verges, amounting to 200 hectares of grassland rich in wildflowers, many of which can only be found elsewhere in nature reserves. The report says that by working with local people with local knowledge, Lincolnshire Wildlife Trust has formed a conservation strategy to bring back the county’s vanishing wildflowers, and trials are now in place with the County Council to fund road verge management for biodiversity.

Pioneer Project: Wildlife-friendly housing development

The fourth pioneer project is a wildlife-friendly housing development at Kidbrooke in London, the result of a partnership between London Wildlife Trust and Berkeley Homes. The report says that Kidbrooke Village will provide more than 4,800 new homes and 35 hectares of varied, semi-natural open space for its residents. The centre of the site is Kidbrooke Park, “which will be designed to be a green corridor for people and wildlife, a natural area weaving between the new houses.” The design includes play areas bordered by species-rich grassland, heather and copses of trees, a chalk stream meandering beside open lawns, and a reed-fringed wetland nestled between high-rise buildings. The reports says that “these green spaces will provide habitat for birds, bees and other wildlife as well as helping with local flood mitigation and water management… These new habitats will also connect to a wider network of green infrastructure beyond the site.”

The Wildlife Trusts argue that if our towns and cities are to be great places for wildlife and people, “we will need the right development, in the right place, done in the right way,” and that Nature Recovery Maps will be an essential guide to help investors and developers make the right decisions.

Environment Secretary announces National Park review

The creation of a Nature Recovery Network received some encouraging news shortly after The Wildlife Trusts’ report was published, with the announcement by Environment Secretary Michael Gove that he would be launching a review of England’s National Parks. [11] The review will consider whether to expand the network of National Parks as well as Areas of Outstanding Natural Beauty. Writing in the Telegraph, the Environment Secretary said: “The creation of National Parks almost 70 years ago changed the way we view our precious landscapes, helping us all access and enjoy our natural world. We want to make sure they are not only conserved, but enhanced for the next generation. Are we properly supporting all those who live in, work in, or want to visit these magnificent places? Should we indeed be extending our areas of designated land?” [12]

As reported by BBC News, the Environment Secretary said that the UK’s population growth, combined with changes in technology and a decline in some habitats, meant it was time to look afresh at these landscapes, and he stressed that the goal of the review was not to diminish the protection of natural areas, but to strengthen it in the face of present-day challenges. [13] Journalist and former government aide Julian Glover has been appointed to carry out the review. Michael Gove said Julian Glover is a “passionate advocate for the countryside” and he wanted him “explicitly to consider how we can extend and improve the protection we give to other precious landscapes.” Julian Glover said: “Our protected landscapes are England’s finest gems and we owe a huge debt to past generations who had the wisdom to preserve them. The system they created has been a strength, but it faces challenges too. It is an honour to be asked to find ways to secure them for the future. I can’t wait to get started and learn from everyone who shares an interest in making England’s landscapes beautiful, diverse, and successful.”

The announcement was welcomed by Margaret Paren, Chair of National Parks England, who said: “As we approach the 70th anniversary of our founding legislation, we look forward to a future where their beauty is enhanced, they are loved and accessible for everyone, and they continue to support thriving communities in these working landscapes.”

The review was also welcomed by Tony Juniper, the Executive Director for Advocacy and Campaigns for WWF-UK and formerly Director of Friends of the Earth, but he also took up The Wildlife Trusts’ call for a Nature Recovery Network, with the warning that we need to do more. “Nature will continue to be at risk unless we have a plan for its recovery enshrined in law through a new Environment Act that’s backed up by a strong watchdog with real powers of enforcement,” he said.

The results of the two recent consultations on farming and planning are expected to be announced later this year.


Photograph: Green bridge over the A21, near Lamberhurst, Kent, giving access to Scotney Castle. © Copyright N Chadwick and licensed for reuse under this Creative Commons Licence. The caption says that the A21 is a 63-mile major trunk road running from Lewisham in Greater London to Hastings, East Sussex. A Wikipedia link reveals that the Lamberhurst bypass was opened on 23 March 2005 and cost £18 million. The green bridge was included in the scheme. In a press release issued on 31st July 2015, Natural England said that the Scotney Castle green bridge “enabled the historic drive to the castle to be preserved, reduced the impact on the local landscape, and was soon being used by dormice” – see Note [8] below. The photograph was taken in 2011.


[1] Towards a Wilder Britain – Creating a Nature Recovery Network to bring back wildlife to every neighbourhood was published by The Wildlife Trusts on May 1st 2018. To download the full report, click here. For a summary, see the item “Nature Recovery Network” on The Wildlife Trusts website.

[2] For the consultation on the future of farming, see the ENA article “The future for farming: UK Government publishes proposals for a post-Brexit agricultural policy”. For the consultation on proposed changes to the National Planning Policy Framework, see the ENA article “Revised National Planning Policy aims to boost house building”. Both consultations closed last month and the results are expected later this year.

[3] See the news story “New proposals for a wilder Britain – critical moment to reverse the decline of nature” on The Wildlife Trusts website.

[4] See the ENA article “UK Government publishes its 25 year plan for the environment” for details of the Government’s environment plan.

[5] See [2].

[6] See the ENA article “Wildlife Trusts Report – Local Wildlife Sites need greater protection”, which describes the state of Local Wildlife Sites as reported at the end of 2014. For a more recent report on the state of nature in the UK, see the ENA article “The State of Nature 2016 – New report examines the causes of wildlife decline in the UK”.

[7] The proposals for future farming policy would replace the Common Agricultural Policy with a system that “pays public money for public goods;” introduce an environmental land management system to replace the current system of basic payments which are largely determined by the amount of agricultural land that a farmer owns; and reform the culture of regulation whilst making it easier for farmers to apply for funding. See the ENA article “The future for farming: UK Government publishes proposals for a post-Brexit agricultural policy”.

[8] In a press release issued on 31st July 2015, titled “Green bridges: safer travel for wildlife”, Natural England announced the publication of a report on green bridges, undertaken by Land Use Consultants on behalf of Natural England. The press release said that the report, which looked at evidence from 56 examples across the world, was the first worldwide study of green bridges, also known as landscape bridges or wildlife overpasses. The scientific study found that green bridges could become an important part of the sustainability of future transport projects by integrating roads and railways into the surrounding landscape, and by providing benefits such as joining up wildlife habitats and connecting colonies, “as they are also used by wildlife as a home in their own right.” Green bridges create safe crossing points for wildlife movement (as well as people), and also benefit pollinators. Natural England said:

“Green bridges are usually planted with a variety of local trees or shrubs and other vegetation. They allow birds, mammals and insects to keep moving despite a road or railway blocking their path. Green bridges are common in Europe and North America, but only a few have been built in Britain… One of the most celebrated spans the A21 at Scotney Castle in Kent in the High Weald Area of Outstanding Natural Beauty (AONB). Completed in 2005 as part of a dual carriageway by-pass for Lamberhurst, it enabled the historic drive to the castle to be preserved, reduced the impact on the local landscape, and was soon being used by dormice.”

Earlier this year, Highways England issued a press release that showed photographs of a green bridge across the A556, near Mere in Cheshire, which was used in March 2017 as the site of an official opening ceremony of a new £192 million bypass. Initially planted with a mixture of hedging and plants, Highways England said “the extensive planting has given birth to a flourishing green border which is providing a safe passage across the road for badgers, voles and other small animals, insects and birds.” See “A556 green bridge is winter wonderland”.

[9] See [7].

[10] The Wildlife Trusts’ report The Way Back to Living Seas, which sets out proposals for a UK Marine Strategy, is available from The Wildlife Trusts’ website by following the link on their news item “The Way Back to Living Seas”.

[11] See the news story “England could have new national parks in Gove review” on the BBC website.

[12] See the Telegraph article “Our National Parks are a magnificent asset that needs protecting. How can we make them even better?” by Michael Gove.

[13] See [11] for the source of these quotations.

New rules for farmers “will help to protect the water environment”

New rules for farmers in England came into force last month

The rules are designed to prevent fertilisers and manure from seeping into watercourses

May 16th 2018

New rules for farmers came into force last month, designed to protect water quality and prevent soil erosion. The rules, which came into force on April 2nd 2018, apply to all farmers in England. The new rules were announced by the Government in a news story last November, which said that the rules would standardise good farming practices, help to protect the water environment, provide a new approach to regulation, and would also help farmers to save money through improved resource efficiency and resilience. [1]

In summary, the rules require farmers to match nutrients to crop and soil needs, and prevent fertilisers, manure, and soil from seeping into watercourses. The Government said the rules “were drawn up with farming and environment stakeholders to recognise and build on the good progress that a great many farmers have made in trying to tackle pollution.” The rules apply to farming and horticultural practices such as planting and harvesting; soil management, which includes ploughing and planting cover crops (“any crop with leaf cover that stops rain falling directly onto the soil”); using and storing manure or fertiliser; and managing livestock.

Assessing the risks of pollution

The Government has published guidance for farmers and landowners on what they must do “to manage manure, fertiliser, and soil to prevent runoff, erosion, and leaching.” [2] There are nine sets of rules. One is a general rule that requires farmers to assess the risks of pollution from the sorts of activities outlined above, taking into account a number of factors that can have an effect on soil erosion or increase the risk of runoff. The guidelines list five factors: distances to inland freshwaters, coastal waters, wetlands, springs, wells and boreholes; the angle of slopes; the presence and condition of land drains; the amount of ground cover; and the type of soil and its condition.

As for the other sets of rules, five are concerned with managing fertilisers and manures, two are concerned with managing soils, and one is concerned with managing livestock:

“The fertiliser rules require farmers to test their soils, then plan and apply their fertiliser or manure to improve soil nutrient levels and meet crop needs. They include minimum storage and spreading distances from water bodies. They also require the farmer to assess weather and soil conditions to reduce the risk of runoff and soil erosion. The remaining rules require farmers to manage livestock by protecting land within five metres of water and reducing livestock poaching [i.e., compacting soil by trampling]. In addition to these rules, farmers are encouraged to incorporate organic fertilisers into the soil within twelve hours of spreading to significantly reduce ammonia pollution.” [3]

Managing fertilisers and manure

The guidelines advise farmers to plan every application of fertiliser or manure, whether they are spread on the land surface, injected into the soil, or mixed with the soil surface layers. [4] Farmers are told to assess the pollution risks, as outlined above, assess the weather conditions and forecasts at the time of application, and match the quantity to crop or soil needs so that no more is used than is necessary. Farmers are also told to check the organic matter content and moisture level of the soil, and to check that their spreading equipment is calibrated and does not leak. Fertilisers or manure must not be used on waterlogged, flooded, or snow-covered soil, or on land where the soil has been frozen for more than 12 hours in the past 24 hours. Whenever they are applied, they should be worked into the soil within 12 hours or as soon as possible after the application.

An extra rule applies if fertilisers or manure are to be used on cultivated agricultural land, which is defined as land that has been ploughed, sowed or harvested at least once in the last year; or land that has received an application of manure or fertiliser at least once in the last three years. In this case, farmers must plan by using the results of a soil test, which must be no more than five years old at the time of application. The test results must show the pH and levels of nitrogen, phosphorus, magnesium, and potassium.

As for the proximity to watercourses, fertilisers must not be used within 2 metres of inland freshwaters, coastal waters, a spring, well or borehole; while manure must not be used or stored within 50 metres of a spring, well or borehole; or within 10 metres of inland freshwaters or coastal waters. The latter limit for applying manure is shortened to 6 metres if precision equipment is used. [5]

A further exception to the use of manure is where the land is managed for breeding wader birds or as a species-rich semi-natural grassland. In this case, manure (but not slurry or poultry manure) can be applied within 10 metres of inland freshwaters and coastal waters if the land is an SSSI (Site of Special Scientific Interest) or is the subject of an Environmental or Countryside Stewardship scheme. However, the manure should not be applied to the water surface, and should only be applied from 1st June to 31st October. There is also a limit to the amount that can be applied in any year, which is no more than 12.5 tonnes per hectare.

Managing soil and livestock

On soil management, as well as the soil test for cultivated agricultural land mentioned above, the guidelines advise farmers to take reasonable precautions to prevent soil loss caused by horticultural or farming activities: “soil loss can lead to erosion and allow pollutants to get into watercourses.” In particular, farmers are told to take reasonable precautions to reduce the risk of pollution when they carry out the following activities: creating farm tracks or gateways; establishing seedbeds, polytunnels or tramlines; cleaning out ditches; installing drainage or irrigation; irrigating crops; and spraying crops with pesticides, herbicides, or fungicides.

Examples of good practice are cited as: planting crops in early autumn and in dry conditions; planting headland rows and beds across the base of sloping land; under-sowing or sowing a cover crop to stabilise soil after harvest; breaking up compacted soil; and establishing grass buffer strips in valleys, along contours, slopes, field edges, and gateways.

A further set of rules are concerned with managing livestock to avoid pollution and soil erosion. Livestock feeders must not be placed within 10 metres of inland freshwaters or coastal waters; or within 50 metres of a spring, well or borehole. Farmers are also told to prevent livestock compacting soil by trampling it within 5 metres of inland freshwaters or coastal waters. As examples of good practice, the guidelines cite moving livestock to prevent soil compaction and soil erosion by riverbanks; putting up fences to keep animals away from watercourses; and wintering livestock on well-drained, level fields.

Inspections and enforcement

The guidelines state that the Environment Agency will be responsible for enforcing the new rules, and will do this through its farm inspections work. These inspections may include checking the distance restrictions; checking for soil erosion that affects a single area of more than 1 hectare; checking for soil compaction on a stretch of land, at least 2 metres wide and 20 metres long, next to an inland freshwater or coastal water; checking for signs of fertiliser use in restricted areas, including excessive vegetation growth on the margins of restricted areas; checking fertiliser records, including records on calibrating fertiliser equipment; checking soil test results; checking for evidence of pollution or for significant risks of pollution; and checking the types of crops that are being planted. If the Environment Agency discovers a breach of the rules, it will help farmers by identifying the changes that need to be made, and agreeing a timescale to make the necessary changes. The Environment Agency may follow this up with a return visit or ask for photographic evidence to check that the changes have been made.

New rules are welcomed by the Rivers Trust

Responding to the announcement of the new rules, the Rivers Trust said last December that “Defra’s new common-sense rules for farming will make a significant difference to the health of rivers.” Arlin Rickard, CEO of The Rivers Trust and Chair of the Catchment Based Approach National Support Group, said:

“We have been working closely with Defra and farmers on the ground to ensure these common-sense but important rules are easy to follow and are set out in a practical and intuitive way. They will provide a clear point of reference for farmers and help maintain healthy soils, crops and livestock as well as reduce diffuse pollution. They will also help farmers save money by using nutrients more efficiently. Our local Rivers Trusts together with the 100 plus Catchment Partnerships that cover England will be promoting the uptake of the rules through our extensive advisor and farmer networks.” [6]

In last year’s news story, the Government said:

“Farming rules for water are part of a whole package of measures to help farmers and land managers look after the environment. The Government is also investing £400 million through Countryside Stewardship schemes which support farmers in creating or restoring precious habitats, and a £12 million farm ammonia reduction grant has incentivised farmers to tackle agricultural emissions. The new rules will not only benefit farming businesses. Clean water helps tourism, fishing, and shellfish businesses to thrive, reduces the cost of treatment, and protects biodiversity. The Environment Agency will roll out the rules through an advice-led approach, working with farmers to meet the requirements before enforcement action is taken. Farmers and land managers will be able to determine what approach is best for their land, through methods such as deciding when it is safe to spread fertilisers.” [7]


Creative Commons Licence
Corvedale Cattle © Copyright Anthony Bloor and licensed for reuse under a Creative Commons Attribution-ShareAlike 4.0 International License. The new rules advise farmers to erect fences to keep cattle away from watercourses.


[1] The news story was published on 30th November 2017. See the GOV.UK web page “New Farming Rules for Water”.

[2] For Defra’s guidance on the new rules, see the GOV.UK web page “Rules for farmers and land managers to prevent water pollution”. The title of the relevant legislation is The Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018.

[3] See [1].

[4] Manure is defined in the guidance as organic materials made from one or more animal, plant or human sources.

[5] The precision equipment is defined specifically in the guidelines as “a trailing hose or shoe band spreader; a shallow injector (no deeper than 10cm); or a dribble bar applicator.”

[6] For the Rivers Trust response, click here. Diffuse pollution refers to water pollution caused by manure, fertiliser or soil seeping into watercourses.

[7] See [2].

Revised National Planning Policy aims to boost house building

UK Government wants to reach target of 300,000 new homes a year

Local authorities will be expected to make more land available for housing

April 18th 2018

Since the Housing and Planning Bill became the Housing and Planning Act in May 2016, the UK Government has produced a number of documents that focus on measures to expedite house building. [1] Those documents include a housing White Paper, published in February 2017; a consultation paper titled Planning and Affordable Housing for Build to Rent, also published in February 2017; and a further consultation paper, titled Planning for the right homes in the right places, published in September 2017. A consultation paper was also published in December 2015, prior to the Housing and Planning Act, which dealt with changes to national planning policy associated with the measures contained in the Act. The Government is now holding a further consultation on changes to the National Planning Policy Framework (NPPF) which reflect the results of those previous consultations, as well as further changes to policy, “beyond those consulted on previously, to help ensure that more land is brought forward for development and that permissions are turned into homes as soon as possible.” [2] The consultation on the revised NPPF opened on March 5th 2018 and will close on May 10th 2018.

The revised National Planning Policy Framework

The consultation paper explains that the National Planning Policy Framework, which was first introduced in 2012, “brought together around 1,000 pages of planning policy and guidance into a single document. Critically, and in line with the Government’s housing ambitions, it established a ‘presumption in favour of sustainable development’.” As well as changes to policy, the revised NPPF also includes structural changes, the main change consisting of a division of the document into clearly defined chapters. The chapters are:

Chapter 1 Introduction
Chapter 2 Achieving sustainable development
Chapter 3 Plan-making
Chapter 4 Decision-making
Chapter 5 Delivering a wide choice of high quality homes
Chapter 6 Building a strong, competitive economy
Chapter 7 Ensuring the vitality of town centres
Chapter 8 Promoting healthy and safe communities
Chapter 9 Promoting sustainable transport
Chapter 10 Supporting high quality communications
Chapter 11 Making effective use of land
Chapter 12 Achieving well-designed places
Chapter 13 Protecting the Green Belt
Chapter 14 Meeting the challenge of climate change, flooding and coastal change
Chapter 15 Conserving and enhancing the natural environment
Chapter 16 Conserving and enhancing the historic environment
Chapter 17 Facilitating the sustainable use of minerals

The Government has set itself the target of delivering 300,000 new homes a year. Introducing the reasons for the proposed changes to the NPPF, the Ministry of Housing, Communities and Local Government states:

“This country does not have enough homes. For decades the number of new homes has not kept pace with rising demand. That has created a market that fails to work for far too many families, resulting in soaring prices and rising rents. The Government is clear that the country needs radical, lasting reform that will allow more homes to be built. The housing White Paper ‘Fixing our broken housing market’ set out a comprehensive strategy to tackle these failures. This comprised planning for the right homes in the right places, building homes faster, diversifying the market and helping people now. Further detail on a number of these reforms was set out in ‘Planning for the right homes in the right places’ in September 2017. Budget 2017 built on this strategy to put us on track to reach 300,000 net additional homes a year. It included additional proposals to change planning policy and legislation to bring forward more land in the right places…”

“Making the most of existing spaces”

The proposed changes to the NPPF place a great deal of emphasis on making the most efficient use of the space available, which applies both to land and to existing buildings. The consultation document says that the revised NPPF “recognises the importance of making the most of existing spaces, making clear that plans should seek more intensive use of existing land and buildings and include minimum density standards in town and city centres and around transport hubs.” The document continues:

“The Government does however recognise that there are locations where meeting needs through more effective use of urban land will not be possible, and in these instances there will be a need to find extra land to deliver the homes needed locally. Where this is the case the Government wants to ensure that these developments deliver the right homes and that the value generated by releasing land is supported by local infrastructure and communities. To this end, the Government is exploring wider measures to support farm diversification and housing in the rural economy.”

To make the most of existing spaces, the Government wants to extend the use of permitted development rights to include upwards extensions to existing buildings, both residential and commercial premises. The document explains:

“The use of permitted development rights to create new homes has played a vital part in increasing housing delivery in recent years. Since April 2015, permitted development rights have created over 30,000 new homes through changes of use from offices, agricultural, retail, and other buildings. The Government is interested in finding more solutions to making the most of the spaces we have in delivering the homes we need in the right places. The Written Ministerial Statement of 5 February 2018 made clear that planning policies and decisions should allow the use of airspace above existing residential and commercial premises to create new homes. This approach makes sure that we are using the space we have available efficiently and reduces the need to build out. The Government is exploring what opportunities there are to further support this approach through a new permitted development right for upwards extensions for new homes where existing buildings are lower than the prevailing roof line. This would be subject to engagement with neighbours. A future consultation will seek views on where best this permitted development right should be applied.”

“Local authorities will be expected to have a clear strategy for using land”

The emphasis on making the most of the land and space available is reflected in Chapter 11 of the revised NPPF, “Making effective use of land.” Local authorities will be expected to have a clear strategy for using land when drawing up local plans. They will also be expected to make more land available for housing, especially in areas of high demand; to make more intensive use of existing land and buildings; to give substantial weight to the value of using suitable brownfield land within settlements for homes; and to take “a flexible approach to policies or guidance that could inhibit making effective use of a site.” Further changes make explicit the need to make more effective use of empty space above shops, “with the proposed policy widening this to refer to other situations where under-utilised land and buildings could be used more effectively.” The proposed changes make it easier to convert retail and employment land to housing where this would be a more effective use. The revised NPPF also says that local authorities should reallocate land where there is no reasonable prospect of an application coming forward for the allocated use, and should also set out “how alternative uses should be considered ahead of a plan review taking place.”

On housing density, local authorities will be expected to avoid building homes at low densities in areas of high demand; and to pursue higher-density housing in accessible locations, “while reflecting the character and infrastructure capacity of each area.” Additionally, the revised policy says that minimum density standards should be used in town and city centres and around transport hubs. The new policy applies this principle to areas where there is a shortage of land for meeting identified development needs, extends the principle to town centres, and indicates that “standards should seek a significant uplift in prevailing densities, unless this would be inappropriate.” The revised policy also proposes that minimum densities should be considered in other parts of the plan area.

A further significant change proposes that “local planning authorities should refuse applications which they consider fail to make effective use of land, in areas where there is an existing or anticipated shortage of land for meeting identified housing needs.”

Local Authorities and Local Plans

As well as the emphasis on effective use, the revised NPPF requires local authorities to take a number of other new factors into account when drafting their local plans. Firstly, Chapter One says that endorsed recommendations of the National Infrastructure Commission may be material when local planning authorities prepare plans or determine planning applications. Chapter Three of the revised NPPF (“Plan-making”) requires local authorities to review their local plans every five years following the date of adoption, “with updates, if necessary, to reflect changing circumstances.” This latter change reflects changes to the Town and Country Planning (Local Planning) (England) Regulations 2012, which came into force on 6 April 2018.

Chapter Five (“Delivering a wide choice of high quality homes”) introduces a new standard method for the calculation of local housing need, and also states that local authorities should adopt clear policies for addressing the housing requirements of groups with particular needs – “students and travellers have been added to the list, as have people who rent their homes.” On affordable housing, Chapter Five includes a requirement that at least 10% of homes on major sites should be available for affordable home ownership, with certain exemptions. Chapter Five also reflects the announcement in the 2017 Budget that “the Government would consult on allowing the development of exception sites to provide entry-level homes suitable for first-time buyers, where a local need is identified.” As a further boost to house building, Chapter Five encourages local authorities to make greater use of small sites, “in order to diversify the opportunities for builders and increase the number of schemes that can be built out quickly.” On the definition of a small site, the revised NPPF proposes that local planning authorities should ensure that at least 20% of the sites allocated for housing in their plans are of half a hectare or less, but the Government says it is open to suggestions on these figures.

On technical matters, Chapter Three (“Plan-making”) reflects a new approach to viability, “through which plans are expected to be clear about the contributions expected in association with development,” while Chapter Four (“Decision-making”) “makes clear that where a proposed development accords with all relevant policies in the plan there is no need for a viability assessment to accompany the planning application.”

Town and Country

Some of the changes in the revised NPPF are specific to towns and rural areas. Chapter Six (“Building a strong, competitive economy”) stresses the importance of supporting business growth and improved productivity, “in a way that links to key aspects of the Government’s Industrial Strategy.” It includes a section on the rural economy and the need to support rural businesses. The new NPPF recognises “the potential need for planning policies and decisions to accommodate sites for local business and community needs outside existing settlements, in ways which minimise the impact of such sites and exploits opportunities to make such locations more sustainable.” The Government says that this approach reflects the fact that the availability of sites to accommodate appropriate development in rural areas may be limited, particularly within existing settlements.

Chapter Seven is concerned with “ensuring the vitality of town centres.” The revised NPPF says that local authorities should look at least ten years ahead in allocating sites to meet the need for town centre uses (“though not necessarily over the full plan period, if longer, given uncertainty in forecasting long-term retail trends”). Chapter Seven also says that town centre boundaries should be kept under review so that identified needs for town centre uses can be accommodated. However, “out of centre sites should be considered only if suitable town centre or edge of centre sites are unavailable or not expected to become available within a reasonable period. ” Additionally, Chapter Seven “removes the expectation that office developments outside town centres are subject to an impact assessment, where the development is over a certain floorspace threshold.”

Protecting (and redefining) the Green Belt

The Government says that the revised NPPF “maintains the strong protections of the Green Belt and retains a high bar before Green Belt land may be released.” Chapter Thirteen, “Protecting the Green Belt,” includes the policy that “certain criteria should be satisfied before ‘exceptional circumstances’ are used to change Green Belt boundaries.” The chapter also says that, where Green Belt is released, prime consideration should be given to land which has been developed previously or which is well-served by public transport.

However, the revised NPPF also makes it clear that “neighbourhood plans may amend detailed Green Belt boundaries, once the need for a Green Belt change has been demonstrated,” with the proviso that the plans are also expected to set out how the impact of removing land from the Green Belt can be offset. A further change allows brownfield land in the Green Belt to be used for affordable housing, “where there is no substantial harm to openness.” This change broadens a previous proposal to allow brownfield land in the Green Belt to be used for ‘starter homes’, “so that, subject to Green Belt protections, all residential developments that contribute to meeting an identified local affordable housing need can use brownfield land, allowing local planning authorities to use this land more flexibly in response to local circumstances.”

The consultation document says that “current policy allows buildings in the Green Belt in association with uses such as outdoor sport and cemeteries, but does not allow material changes in the use of land for such purposes, even if there would be no harm to openness.” The revised NPPF says that material changes of use that preserve openness should not be regarded as inappropriate development in the Green Belt, which would allow for a more consistent approach. Additionally, the revised NPPF says that facilities for burial grounds and allotments, rural exception sites, and development brought forward under a Neighbourhood Development Order, should also not be regarded as inappropriate development in the Green Belt.

Taking into account the Government’s 25 year Environment Plan

Chapter Fifteen of the revised NPPF, “Conserving and enhancing the natural environment,” has been updated to reflect the Government’s 25 Year Environment Plan, which was published earlier this year. [2] It includes additional policy on strengthening existing habitat networks, taking air quality fully into account, clarifies that development within National Parks and Areas of Outstanding Natural Beauty should be limited, and also clarifies the implications for policy on areas defined as Heritage Coast. The revised NPPF also “strengthens protection for ancient woodland and other irreplaceable habitats, by making clear that development resulting in their loss or deterioration should be wholly exceptional.” Additionally, the policy “maintains a high level of protection for individual aged or veteran trees found outside these areas.” The Government says that this policy strikes a balance between protecting these important natural assets, while allowing development to proceed in the very limited circumstances where it would have significant public benefits, “but we welcome views on this during the consultation period. In particular, we are interested in views on how best to protect aged and veteran trees without preventing those important development schemes which are in the public interest.” The concern for veteran trees is also reflected in Chapter Two, “Achieving sustainable development.” The Government says that the current NPPF includes examples of policies that provide a specific reason for restricting development; these examples will be replaced in the revised NPPF with a defined list, “which includes ancient woodland and aged or veteran trees.”

The 25 year Environment Plan is also reflected in Chapter Sixteen of the revised NPPF, “Conserving and enhancing the historic environment.” The updated policy acknowledges that “World Heritage Sites are recognised internationally for their Outstanding Universal Value” – this international recognition “forms part of their significance and should be taken into account.” The revised policy also says that when considering the impact of a proposed development on a designated heritage asset, “decision-makers should give great weight to the asset’s conservation irrespective of whether the potential harm to its significance amounts to ‘less than substantial harm’, ‘substantial harm’, or ‘total loss of significance’.”

Responding to Climate Change

Chapter Fourteen of the new NPPF is titled “Meeting the challenge of climate change, flooding and coastal change.” Among the changes, the chapter refers to the risk of overheating from rising temperatures and “makes clear that planning policies should support measures to ensure the future resilience of communities and infrastructure to climate change.” In particular, the new policy says that local plans should have regard to the cumulative impacts of flood risk, “rather than just to or from individual development sites.” It also clarifies the policy on the exception test that may need to be applied when considering development in locations at risk of flooding. Additionally, a paragraph has been added on sustainable drainage systems in major developments, which incorporates a “Written Ministerial Statement of 18 December 2014.”

Some changes are associated with the Government’s Clean Growth Strategy, which “sets out the Government’s plans for consulting on energy performance standards in Building Regulations later this year.” [3] The consultation document says that local authorities can play an important role in improving the energy performance of buildings in line with the ambitions of the Clean Growth Strategy; this role “will be considered further as the Government develops its consultation proposals.” Policy changes in Chapter Fourteen reflect the fact that “local planning authorities are tied to national technical standards, and there is limited scope to extend local ambition.”

“Designs should prioritise pedestrian and cycle movements”

The above account summarises most of the significant changes to the NPPF. Other changes are concerned with the following:

• “Promoting healthy and safe communities” – Chapter Eight stipulates that policies and decisions should consider the social and economic benefits of estate regeneration, and recognises the role that planning can play in promoting social interaction and healthy lifestyles.
• “Promoting sustainable transport” – Chapter Nine reflects the Government’s expectations that local authorities should identify additional development opportunities arising from strategic infrastructure investment, and that designs should prioritise pedestrian and cycle movements, followed by access to high quality public transport (“so far as possible”), and recognise the importance of creating well-designed places.
• “Supporting high quality communications” – Chapter Ten indicates that local plans should set out expectations in relation to the delivery of high quality digital infrastructure, “which provides access to services from a range of providers. This reflects government support for the further expansion of electronic communications networks, including next generation mobile technology and full fibre broadband connections, and the role that planning can play in this alongside other regulatory frameworks.”
• “Achieving well-designed places” – Chapter Twelve says that “outstanding or innovative designs” should not be given great weight where they are in conflict with local design policies or would not be sensitive to their surroundings.

Regarding Chapter Seventeen, “Facilitating the sustainable use of minerals,” the Government says that “as planning for minerals is the responsibility of minerals planning authorities, the Government is interested in views on whether the revised planning policy for minerals that we are consulting on would sit better in a separate document, alongside the Government’s planning policy for waste.”

Finally, the Government says it will continue to explore options for reforming developer contributions, to be delivered through regulations. The Government is also considering what further planning reforms could support the objective of bringing forward more land for development and ensuring that permissions are turned into homes as soon as possible. As mentioned above, these include a new permitted development right for upwards extensions, and wider measures to support farm diversification and housing in the rural economy, including “more effective ways of bringing agricultural land forward for housing.”

The current consultation on the revised NPPF closes on May 10th 2018.


Photograph: Affordable housing, Damson Way, Suckley, Worcestershire, 2008 © Copyright Peter Whatley and licensed for reuse under this Creative Commons Licence. The Government’s definition of affordable housing was broadened in the Housing and Planning Act 2016, which caused much controversy when the bill was scrutinised in the House of Lords. Peers expressed concerns that starter homes were included in the definition of affordability, pointing out that starter homes were still unaffordable to many people, and that the starter home initiative would lead to a reduction in other forms of affordable housing. See the ENA article: “The Housing and Planning Act 2016 – A Review”.


[1] See the ENA article: “The Housing and Planning Act 2016 – A Review”. Further articles on housing and planning can be found by using the search facility on this website.

[2] The consultation paper National Planning Policy Framework: Consultation proposals is a PDF document which can be downloaded from the GOV.UK website by clicking here. In chronological sequence, the previous consultations and papers that have fed into the revised NPPF are as follows:

a) National Planning Policy: consultation on proposed changes (December 2015). The consultation sought views on specific changes to national planning policy aimed at supporting the delivery of new homes. The changes covered the following areas: broadening the definition of affordable housing “to expand the range of low cost housing opportunities”; supporting the delivery of starter homes; increasing the density of development around commuter hubs to make more efficient use of land in suitable locations; supporting sustainable new settlements; supporting development on brownfield land and small sites; and supporting the delivery of housing allocated in local plans.

b) The housing White Paper Fixing our broken housing market (February 2017). The White Paper set out the Government’s plans to boost the supply of new homes in England. It included measures “to ensure we plan for the right homes in the right places; build homes faster; diversify the housing market; and help people now.” The consultation also sought views on changes to planning policy and legislation in relation to planning for housing, sustainable development, and the environment.

c) Planning and Affordable Housing for Build to Rent – a consultation paper (February 2017). This consultation sought views on planning measures to support an increase in Build to Rent schemes across England. Key proposals were changes to the NPPF to support and to increase the number of new Build to Rent homes, and the provision of Affordable Private Rent homes as the main form of affordable housing provision in Build to Rent schemes. The consultation also sought to promote the availability of longer tenancies (3 years or more) in Build to Rent accommodation. Local authorities would be encouraged to plan for Build to Rent schemes, with Affordable Private Rent serving as a substitute for other types of affordable housing.

d) Planning for the right homes in the right places: consultation proposals (September 2017). A consultation on further measures set out in the housing White Paper to boost housing supply in England. The consultation set out a number of reforms to the planning system in order to increase the supply of new homes and to increase local authority capacity to manage growth. The proposals included: “a standard method for calculating local authority housing need; giving neighbourhood planning groups greater certainty on the level of housing need to plan for; a statement of common ground to improve how local authorities work together to meet housing and other needs across boundaries; making the use of viability assessments simpler, quicker and more transparent; and increased planning application fees in those areas where local planning authorities are delivering the homes their communities need.”

Links to all of the above documents can be found on the GOV.UK web page “Draft revised National Planning Policy Framework”.

[3] On the Government’s Clean Growth Strategy, see the ENA article: “UK Government publishes ‘The Clean Growth Strategy'”.

The future for farming: UK Government publishes proposals for a post-Brexit agricultural policy

Defra proposes to replace the Common Agricultural Policy with a new system that “pays public money for public goods”

Environmental land management, “underpinned by natural capital principles,” will be the cornerstone of future agricultural policy in England

March 21st 2018

Following the publication of its 25 year plan for the environment, the UK Government is now seeking views on proposals for the development of a new agricultural policy. [1] The ten-week consultation period opened on 27th February and will close on 8th May 2018. On the GOV.UK website, Defra (the Department for the Environment, Food & Rural Affairs) says: “Leaving the European Union and the Common Agricultural Policy will give us the chance for reform. We want to know your thoughts on the future of agricultural policy in England.” [2] The proposals are set out in a consultation document titled Health and Harmony: the future for food, farming and the environment in a Green Brexit. Supplementary information includes an annex on stakeholder proposals, an annex on Countryside Stewardship options, and an evidence compendium, which provides “a detailed assessment of the current state of agriculture in the UK to underpin the proposals laid out in the consultation paper.” The evidence compendium contains detailed statistics on farm economics and accounts, food production, and environmental land management. [3]

“The case for change”

In his foreword to the consultation document, Michael Gove, Secretary of State for the Environment, says:

“For more than forty years, the EU’s Common Agricultural Policy (CAP) has decided how we farm our land, the food we grow and rear, and the state of the natural environment. Over that period, the environment has deteriorated, productivity has been held back, and public health has been compromised… The environmental damage we have suffered while inside the CAP has been significant. Soil health has deteriorated. Farmland bird numbers have dropped. Precious habitats have been eroded. And at the same time a system of subsidy skewed towards those with the biggest landholdings has kept land prices and rents high, prevented new talent coming into farming, and held back innovation.”

Chapter One of the document makes the case for change. It explains that the CAP involves three types of payments to farmers: Direct Payments, comprising a Young Farmers Scheme and a Basic Payment Scheme with a ‘greening’ component; price support for food producers; and rural development schemes which include agri-environmental measures. [4] Direct Payments have been reformed several times and were previously linked to production but are now largely based on the size of agricultural land that a farmer owns, as measured by the number of hectares. Defra says that of all the different types of farming, grazing livestock is the sector that is most dependent on Direct Payments, sheep farming in particular: “Those sectors in which a high proportion of farmers currently depend on Direct Payments just to break even are often located in the most remote, wild and beautiful parts of the UK… For example, the distinctive character of the Lake District landscape has been shaped through long association with sheep farming, one of the sectors currently most dependent on Direct Payments.”

The document concedes that the CAP has produced some environmental improvements, but it also says that the overall positive impact has been limited. In making the case for change, Defra says that the CAP has not been effective enough at reversing environmental damage caused by agricultural practices which have increased negative pressures on the environment through pollution and practices that have led to habitat and species loss. The Executive Summary (p.6) states:

“The CAP introduced some of the world’s first agri-environment schemes, making progress towards improving our environment. Significant reforms have helped to shift the CAP away from the ‘butter mountains’ and ‘wine lakes’ of the 1980s. Decoupling Direct Payments from production has reduced some of the incentives to produce in an environmentally-harmful way. Despite this, the CAP remains flawed. Even though we have some of the most innovative farmers in the world, land-based subsidies can undermine incentives for widespread productivity improvement and are bad value for taxpayers. Efforts to enhance our environment have also been limited by the bureaucratic structure of the CAP. It has imposed unnecessary regulatory burdens and failed to reward some public goods adequately, such as measures to improve water quality and soil health.”

A period of transition

About a third of the 64-page consultation document is taken up with the Common Agricultural Policy and its impact, and on the transitional arrangements that will come into place following the UK’s anticipated departure from the EU. In a section titled “Moving away from the Common Agricultural Policy in England,” there are chapters on “Reform within the CAP,” “An agricultural transition,” and “A successful future for farming.” Each chapter concludes with a number of questions for consultation. Chapter Four (“a successful future”) also includes sections on “Farming excellence and profitability,” “Agricultural technology and research,” and “Labour: a skilled workforce.”

In summary, the Government is proposing to continue with the Direct Payments system for a limited period in England, but will gradually reduce payments starting with those who receive the most under the current system. While reducing Direct Payments, it will also introduce a new system of payments based on environmental land management, which will replace the current Countryside Stewardship scheme. The current system of Direct Payments will eventually be phased out completely. The consultation is seeking views on how the phasing out of Direct Payments can best be achieved, and discusses several possibilities based on different financial arrangements, including the possibility that farmers may want to quit farming altogether. Meanwhile, the Government says it will maintain the current level of funding for agriculture across the whole of the UK until the end of the current parliament. The Executive Summary (p.7) states:

“We will formally leave the European Union in March 2019. The government anticipates that we will agree an implementation period for the whole country with the EU lasting for around another two years. Once we have the freedom to move away from the CAP, there will be an ‘agricultural transition’ period in England… In England, Direct Payments will continue during the agricultural transition… We want our future policy to provide an enabling environment for farmers to improve their productivity and add value to their products, so they can become more profitable and competitive. We therefore propose to further reduce and phase out Direct Payments in England completely by the end of the ‘agricultural transition’ period, which will last a number of years beyond the implementation period.”

Defra is proposing to make some changes to how the CAP is administered within the implementation period. Chapter Two of the document says that complying with the CAP regulations “presents a challenge to farmers and land managers, policy makers and delivery agencies. The administration of the Basic Payment scheme and Countryside Stewardship scheme can restrict access through complicated application systems and burdensome evidence requirements.” Defra is proposing to simplify the current system to make it easier for farmers to apply for Basic Payments and for Countryside Stewardship funds, and is seeking views on how this simplification can best be achieved. One question presents four options for simplification of the current arrangements under the CAP, and respondents are asked to indicate the three that are most appealing. A second question asks: “How can we improve the delivery of the current Countryside Stewardship scheme and increase uptake by farmers and land managers to help achieve valuable environmental outcomes?”

On the issue of Direct Payments, having discussed the possibilities based on different financial arrangements, the consultation document asks four questions, as follows:

• “What is the best way of applying reductions to Direct Payments?” Respondents are asked for their preference from three possibilities: a) applying progressive reductions, with higher percentage reductions applied to amounts in higher payment bands (respondents are also asked to provide views on the payment bands and percentage reductions that should be applied); b) applying a cap to the largest payments; and c) other.
• “What conditions should be attached to Direct Payments during the ‘agricultural transition’?” Respondents are asked to indicate their preferences from a list of four options.
• “What are the factors that should drive the profile for reducing Direct Payments during the ‘agricultural transition’?”
• “How long should the ‘agricultural transition’ period be?”

Research and innovation: Investing in skills and technology

Looking towards the future, the document stresses the need for farming to embrace new technology and invest in skills, which it says will enable farmers to be more competitive. Defra says “there is a huge opportunity for UK agriculture to improve its competitiveness – developing the next generation of food and farming technology, adopting the latest agronomic techniques, reducing the impact of pests and diseases, investing in skills and equipment, and collaborating with other farmers and processors.” The consultation document asks four questions on skills and capital investment:

• “How can we improve the take-up of knowledge and advice by farmers and land managers?” Respondents are asked to rank their top three preferences from a list of six options.
• “What are the main barriers to new capital investment that can boost profitability and improve animal and plant health on-farm?” Respondents are asked to rank their top three issues from a list of seven.
• “What are the most effective ways to support new entrants and encourage more young people into a career in farming and land management?”
• “Does existing tenancy law present barriers to new entrants, productivity and investment?”

On agricultural innovation, the document includes a case study of work at Harper Adams University in Shropshire where, in 2017, a team of researchers successfully grew a crop of barley “using only autonomous vehicles and drones and without a human setting foot in the field.” The case study reports: “The Hands Free Hectare project was a major step in revolutionising how we feed the world whilst helping to protect the environment. To limit damage to the soil for future harvests, and increase efficiency, the team employed a small modified tractor and combine equipped with cameras, sensors and GPS systems. Drones monitored the field, while a robot scout collected plant samples for inspection.”

The Government says it wants to pioneer new approaches to crop protection and encourage more commercial research to improve plant breeding and agronomic techniques: “New approaches, such as vertical farming, can harness the combined power of robotics, photonics, artificial intelligence and smart energy management systems, as well as plant biotechnology.” Respondents are asked three questions on research and innovation, as follows:

• “What are the priority research topics that industry and government should focus on to drive improvements in productivity and resource efficiency?” Respondents are asked to rank in order of importance the top three topics from a list of seven.
• “How can industry and government put farmers in the driving seat to ensure that agricultural R&D delivers what they need?” Respondents are asked to rank in order of importance the top three options from a list of five.
• “What are the main barriers to adopting new technology and ideas on-farm, and how can we overcome them?”

As well as new technology, the Government also stresses the need to invest in skills. Three questions seek the views of respondents on this topic:

• “What are the priority skills gaps across UK agriculture?” Respondents are asked to rank in order of importance the top three options from a list of seven.
• “What can industry do to help make agriculture and land management a great career choice?”
• “How can government support industry to build the resilience of the agricultural sector to meet labour demand?”

“Farming is crucial to achieving the goals of the 25 Year Environment Plan”

As for future agricultural policy, Defra says that the CAP will be replaced with a new system that “pays public money for public goods,” whilst the proposed system of environmental land management will be underpinned by natural capital principles (the term “underpinned” is used several times in the consultation paper). [5] The Executive Summary (p.8) states:

“From the end of the agricultural transition, a new environmental land management system will be the cornerstone of our agricultural policy in England. The system will help us to deliver our manifesto commitment to be the first generation to leave the environment in a better state than we inherited it. Farming is crucial to achieving the goals set out in our recently published 25 Year Environment Plan. A new environmental land management system will help us to preserve the investment in our countryside that has already been made and delivered by farmers. It will consist of a new scheme that pays providers for delivering environmentally beneficial outcomes, and will provide support for farmers and land managers as we move towards a more effective application of the ‘polluter pays’ principle. Our new environmental land management system will be underpinned by natural capital principles, so that the benefits the natural environment provides for people and wildlife are properly valued and used to inform decisions on future land management. The new system aims to deliver benefits such as improved air, water and soil quality; increased biodiversity; climate change mitigation and adaptation; and cultural benefits that improve our mental and physical well-being, while protecting our historic environment.”

Implementing the new policy

The rest of the document is titled “Implementing our new agricultural policy in England,” with a further section titled “The framework for our new agricultural policy.” There are eight chapters on implementing the new policy, under the following headings:

• Public money for public goods;
• Enhancing our environment;
• Fulfilling our responsibility to animals;
• Supporting rural communities and remote farming;
• Changing regulatory culture;
• Risk management and resilience;
• Protecting crop, tree, plant and bee health; and
• Ensuring fairness in the supply chain.

The Government’s aspirations for the future of farming are summarised in the Executive Summary (p.6):

“We will incentivise methods of farming that create new habitats for wildlife, increase biodiversity, reduce flood risk, better mitigate climate change, and improve air quality by reducing agricultural emissions. We will achieve this by ensuring that public money is spent on public goods, such as restoring peat bog and measures which sequester carbon from the atmosphere; protecting dry stone walls and other iconic aspects of our heritage; and reducing disease through new initiatives that better monitor animal health and welfare.”

“Public money for public goods”

Chapter Five describes the sort of public goods that the future policy will support. These are: environmental improvements and protection; better animal and plant health and better animal welfare; improvements to productivity and competitiveness; “preserving rural resilience, traditional farming and landscapes in the uplands;” and enhancements to public access to the countryside. With future generations in mind, the document says that protecting and enhancing the environment “could be considered the pre-eminent public good.” The Government wants to see improvements to soil health through better land management practices; improvements to water quality; better air quality, with the emphasis on reducing ammonia emissions [6]; increased biodiversity; climate change mitigation [7]; and “enhanced beauty, heritage, and engagement with the natural environment.” Respondents to the consultation are asked to rank in order of importance their top three of these six environmental outcomes.

The Government also wants to set high standards for animal health and welfare, and improvements in biosecurity to protect “crops, trees, plants and bees.” On improvements to productivity, the document stresses again the importance of innovation. Defra says that innovations – “such as technology, data science, gene-editing, improved tracking and traceability of livestock, or new plant biosecurity measures” – can increase productivity, help to safeguard the public goods of animal and human health, and “ensure we better protect the environment.”

Hill farming is singled out as needing particular support under the new regime, as it is the sector that is most dependent on Direct Payments under the current system. The Executive Summary (pp.7-8) states:

“We recognise that some sectors may find it more difficult than others to adapt – for example, those located in the most remote, wild and beautiful parts of England. We recognise the environmental and cultural value of our rural landscapes and traditional ways of life, including areas such as the uplands. The uplands have the potential to benefit from new environmental land management schemes, given the nature of their landscapes and the many public goods that they deliver, such as biodiversity, flood risk mitigation, and carbon sequestration. We will explore possible options on how we can best support such areas.”

Respondents to the consultation are asked to rank in order of importance their top three public goods that the Government should support. There are six options: world-class animal welfare; high animal health standards; protection of crops etc.; improved productivity; the preservation of upland landscapes; and public access to the countryside. Respondents are also asked if there are any other public goods that the Government should support.

Environmental outcomes

Chapter Six (“Enhancing our environment”) provides more detail of what a new environmental land management system could involve: “A new environmental land management system, underpinned by natural capital principles, would contribute to delivering against many of the key outcomes set out in the 25 Year Environment Plan and the Clean Growth Strategy. These include: clean air; clean and plentiful water; thriving plants and wildlife; reduced risk of harm from environmental hazards such as flooding and drought; using resources from nature more sustainably and efficiently; enhanced beauty, heritage and engagement with the natural environment; and mitigating and adapting to climate change.” The document says that a new environmental land management system could involve some or all of the following: new environmental land management schemes, such as support for wetland creation, woodland creation, or peatland restoration; funding for collaborative projects; capital grants; a ‘user friendly’ design to improve administration of the scheme; and innovative funding and support mechanisms.

Several case studies are presented which illustrate the sort of environmental improvements that have already been achieved under the current system [8], and the chapter concludes with further questions for consultation. The first question lists eleven outcomes (such as species recovery, soil quality, and cultural heritage), and asks respondents to select which outcomes “would be best achieved by incentivising action across a number of farms or other land parcels in a future environmental land management system.” Three further questions are as follows:

• “What role should outcome-based payments have in a new environmental land management system?”
• “How can an approach to a new environmental land management system be developed that balances national and local priorities for environmental outcomes?”
• “How can farmers and land managers work together or with third parties to deliver environmental outcomes?”

Animal welfare and animal health

Chapter Seven of the document, titled “Fulfilling our responsibility to animals,” is devoted to animal health and welfare. Defra says that the UK has led the way “in making significant welfare advances by banning the use of close confinement sow stalls for pigs and the use of veal crates back in the 1990s. In addition to our plans to make CCTV in slaughterhouses in England compulsory, we also propose to take early steps to control the export of live animals for slaughter as we leave the EU.” The consultation document says that animal welfare is one of the public goods that the Government could support in the future:

“During the agricultural transition, we could pilot schemes that offer targeted payments to farmers who deliver higher welfare outcomes in sectors where animal welfare largely remains at the legislative minimum. Payments could also be made to farmers who trial a new approach or technology which could improve welfare outcomes but which is not an industry standard.”

On animal health, the Government is proposing to work with industry “to develop an ambitious plan to tackle endemic disease and drive up animal health standards. A clear vision and programme of partnership action will help us to tackle non-statutory endemic disease and health conditions in the form of an Animal Health Pathway.” A further proposal is to provide targeted support for priority disease control and health schemes, “learning lessons from the Bovine TB programme in England and schemes elsewhere in the UK and overseas.” Respondents are asked three questions on the topic of animal welfare and animal health:

• “Should government set further standards to ensure greater consistency and understanding of welfare information at the point of purchase?” Respondents are asked to indicate a single preference from five options.
• “What type of action do you feel is most likely to have the biggest impact on improving animal health on farms?” Respondents are asked to rank three out of ten choices in order of importance.
• “How can the government best support industry to develop an ambitious plan to tackle endemic diseases and drive up animal health standards?”

Hill farming and rural businesses

As mentioned above, hill farming is singled out as needing particular support under the new regime, as it is the sector that is most dependent on Direct Payments under the current system. Chapter Eight of the document says that places like the Lake District, now a World Heritage Site, represent a significant part of our heritage, “bringing a wealth of environmental, archaeological and recreational value.” The particular problems faced by hill farmers are explained as follows:

“Since 1975, hill farming has traditionally been supported through financial payments to Less Favoured Areas. In England, Less Favoured Areas are divided into two groups, with the more challenging areas classified as Severely Disadvantaged Areas. These tend to be upland areas. The majority of farms in Severely Disadvantaged Areas (but not all) are grazing livestock businesses with sheep or cattle, although dairy farms and forestry are also important in some areas. Farming activity in these areas is more restricted than in lowland areas due to poor soil fertility and steep hill slopes. Heather moorland dominates the landscape, which is of poor nutritional value to livestock, requiring a larger area of land to produce the same amount of livestock than lowland areas. These limitations mean most upland farms have fewer opportunities to improve their productivity than lowland farms. Compared to lowland farms, farms within the Severely Disadvantaged Areas have less opportunity to diversify. Where they have diversified, they have a lower income from diversified enterprises. Agri-environment schemes also tend to make a greater contribution to average income than lowland farms.”

Defra says that many upland areas have the potential to benefit from new environmental land management schemes, and can encourage biodiversity, protect water quality, and store carbon. Producing high-quality food and diversification into areas such as energy generation, tourism, or commercial forestry, are mentioned as the sort of opportunities that leaving the EU could provide. However, “we recognise that these will be defined by the surrounding landscape and by investment potential.” The Government says that a clear vision for the uplands will be an important part of its agricultural policy, “and we want to explore what this should be.” The Government also says it wants to support rural businesses by measures, for example, to improve broadband connectivity which, in agriculture, “can support precision farming, including environmental sensing systems.” Respondents are asked three questions on upland areas and rural businesses:

• “How should farming, land management, and rural communities continue to be supported to deliver environmental, social, and cultural benefits in the uplands?”
• “There are a number of challenges facing rural communities and businesses. Please rank your top three options by order of importance.” The eight options include broadband connectivity, affordable housing, and transport connectivity.
• “With reference to the way you have ranked your answer to the previous question, what should government do to address the challenges faced by rural communities and businesses post-Brexit?”

“Changing regulatory culture”

Defra says that farmers are currently required to comply with a broad range of legislation, covering environmental protection and animal health and welfare. The range includes rules that prevent the over-abstraction of water sources and animal traceability requirements designed to prevent the spread of disease. However, Defra also says that the current system puts excessive burdens on farmers and can be very rigid in its application. For instance, it says that an incomplete record or the loss of one cattle ear tag can sometimes lead to substantial reductions in payments. As part of a future agricultural policy, Defra says it wants to make regulation less disproportionately punitive and rigid, without relaxing standards:

“There is scope to raise regulatory standards in some areas to maintain and enhance standards. In others, we can look at moving away from disproportionate enforcement that can heavily penalise some farmers for minor errors. We will enable a new regulatory culture in which standards are upheld and their enforcement is less disproportionately punitive and rigid in its application, without weakening our standards. We have considered various inspection and enforcement methods, which could include greater use of remote sensing and risk-based inspection, and advice courses and civil sanctions to enforce regulations.”

The Government says it will be conducting a comprehensive review of the current inspections regime, which will investigate “how inspections can be removed, reduced or improved to lessen the burden on farmers while maintaining and enhancing our animal, environmental, and plant health standards.” Respondents to the consultation are asked three questions on regulation:

• “How can we improve inspections for environmental, animal health, and welfare standards?” Respondents are asked to indicate their preferred options from a list of six.
• “Which parts of the regulatory baseline could be improved, and how?”
• “How can we deliver a more targeted and proportionate enforcement system?”

“Risk management and resilience”

Three chapters of the consultation document deal in turn with risk management; protecting crop, tree, plant and bee health; and ensuring fairness in the supply chain. On risk management and resilience, Defra says that “the best way of improving resilience in the farming sector is to support increases in farm productivity. Profitable farms are more resilient with readier access to capital. Our immediate focus, therefore, will be on improving productivity and profitability so farm businesses can be more self-reliant and invest for the lean years as other sectors do.” However, it also says that fewer than one in five farmers currently buy agricultural insurance. The Government says it is reluctant to subsidise the cost of risk-management products as this can distort the market. Instead, it recommends buying into innovative new commercial products such as a form of insurance known as index insurance, which “differs from standard insurance by triggering payouts based on an agreed-upon index or measurement being met, rather than by actual losses suffered by the insured party. Index insurances typically require less farm-specific data than other insurances and so are easier to administer.” Respondents are asked three questions on this topic:

• “What factors most affect farm businesses’ decisions on whether to buy agricultural insurance?” Respondents are asked to rank in order of importance their top three options from a list of seven.
• “What additional skills, data and tools would help better manage volatility in agricultural production and revenues for (a) farm businesses and (b) insurance providers?”
• “How can current arrangements for managing market crises and providing crisis support be improved?”

“Protecting crop, tree, plant, and bee health”

Defra says that farmers must be able to protect their crops whilst people must be protected from the risks posed by pesticides, both to themselves and the environment. As part of a future agricultural policy, the Government is proposing an “integrated pest management” approach:

“Strong regulation of pesticides is essential to limit the risks, but this should be supplemented by integrated pest management. This means using all the available tools to protect crops, with the least possible use of pesticides. Steps that can be taken include crop rotation, the use of biopesticides, and encouraging natural predators. There is the potential for the greater use of plant breeding techniques and making better use of genetics and the resources held in gene banks to ensure their natural resilience to pests and diseases. By making integrated pest management central to our approach to crop protection, the government can encourage wider investment in research and development.”

Respondents are asked for their views on three questions:

• “Where there are insufficient commercial drivers, how far do you agree or disagree that government should play a role in supporting: a) industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees; b) landscape recovery following pest and disease outbreaks, and the development of more resilient trees; and c) the development of a biosecure supply chain across the forestry, horticulture and beekeeping sectors.”
• “Where there are insufficient commercial drivers, what role should government play in: a) supporting industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees; and b) promoting landscape recovery following pest and disease outbreaks, and the development of more resilient trees.”
• “What support, if any, can the government offer to promote the development of a biosecure supply chain across the forestry, horticulture and beekeeping sectors?”

“Ensuring fairness in the supply chain”

Defra says that most farmers are comparatively small-scale sellers who deal with a smaller number of comparatively large-scale processors and retailers. It recommends that farmers come together in the form of agricultural cooperatives: collaborative organisation, it says, will enable them to access new markets and reduce risks, and also provide them with more bargaining power:

“In some sectors, farmers can give themselves greater power to negotiate contracts and market their produce by coming together in Producer Organisations. We propose to maintain the special status of Producer Organisations, including derogations from competition rules. Collective decision-making is not the traditional model for UK farmers, but the modern supply chain means attitudes have to change. Farmers could benefit from recognising how much more strength they can achieve through cooperation.”

Respondents are asked for their views on three questions concerning collaboration and the food supply chain:

• “How can we improve transparency and relationships across the food supply chain?” Respondents are asked to rank in order of importance their top three options from a list of four. The options include the promotion of Producer Organisations, the introduction of statutory codes of conduct, and improvements to the provision of data.
• “What are the biggest barriers to collaboration amongst farmers?”
• “What are the most important benefits that collaboration between farmers and other parts of the supply chain can bring? How could government help to enable this?”

Devolved government and a common framework

The final section of the consultation document is titled “The framework for our new agricultural policy.” There are three chapters that deal in turn with devolution, international trade, and a proposal to present parliament with an Agriculture Bill. Because of devolved powers, the new agricultural policy will only apply to England. In the Executive Summary, however, the consultation document says that the Government’s vision of the future for agriculture is a vision that could work for the whole of the UK, “but we recognise that devolution provides each administration with the powers to decide its own priorities.” For instance, on the phasing out of Direct Payments in England and its gradual replacement with funding for environmental land management schemes, Defra says that the devolved administrations will have the flexibility to target support in a way that best suits their circumstances. This raises the question of how much flexibility will the devolved powers have, and whether England will end up with a completely different system of rules and regulations for agriculture compared to the rest of the UK. This issue is discussed in Chapter Thirteen, titled “Devolution: maintaining cohesion and flexibility,” which recognises the need for some sort of common framework across the UK. It states:

“Leaving the European Union will be an important step in the devolution of agriculture. Under the existing constitutional settlements, agriculture is devolved in Scotland, Wales and Northern Ireland. However, many of the rules in these areas are currently set at the EU level, although some discretion is allowed in Direct Payments to farmers; and each administration has a rural development programme that they deliver (such as agri-environment schemes and rural economic growth). The devolved administrations and the UK government are working together to determine where common frameworks need to be established in some areas that are currently governed by EU law, but are otherwise within areas of competence of the devolved administrations or legislatures (as agreed by the Joint Ministerial Committee (EU Negotiations)).”

Defra says that the Joint Ministerial Committee for EU Negotiations has agreed three principles regarding common frameworks. The first is that common frameworks will be established where they are necessary (for instance, among other reasons, in order to ensure compliance with international obligations). The second is that “frameworks will respect the devolution settlements and the democratic accountability of the devolved legislatures.” The third is that “frameworks will ensure recognition of the economic and social linkages between Northern Ireland and Ireland and that Northern Ireland will be the only part of the UK that shares a land frontier with the EU. They will also adhere to the Belfast (Good Friday) Agreement.”

Respondents are asked for their views on two questions regarding devolution. The first asks, “With reference to the principles set out above, what are the agriculture and land management policy areas where a common approach across the UK is necessary?” The second asks: “What are the likely impacts on cross-border farms if each administration can tailor its own agriculture and land management policy?” The discussion of common frameworks suggests that “cross-border farms” means farms that straddle the borders between England and Wales or between England and Scotland. The problems that might arise for farms that straddle the border between the North and South of Ireland are not discussed.

International trade following Brexit

Chapter Fourteen discusses the opportunities for new trade agreements post-Brexit and the kinds of agreements that could be negotiated. Defra says that the EU is the UK’s biggest trading partner for agricultural products, “so our future relationship with the EU 27 is of vital importance.” The chapter continues:

“The government is committed to securing a deep and special partnership with the EU, including a bold and ambitious economic partnership. The UK wants to secure the freest trade possible in goods and services between the UK and the EU. Ensuring as frictionless trade as possible for our agricultural sectors is particularly important where much of the produce is perishable and time is critical. The government is committed to securing continuity in the effect of existing EU Free Trade Agreements and other EU preferential arrangements. Through membership of the EU, the UK is currently party to around 40 international trade agreements covering over 65 countries… In the future, the UK will be in a position to independently exercise its existing rights as a World Trade Organization (WTO) member and will continue to be subject to the full obligations of WTO membership. WTO agreements could represent a framework for our future agriculture policy.”

The chapter concludes with three questions for respondents:

• “How far do you agree or disagree with the broad priorities set out in the trade chapter?”
• “How can government and industry work together to open up new markets?”
• “How can we best protect and promote our brand, remaining global leaders in environmental protection, food safety, and in standards of production and animal welfare?”

An Agriculture Bill

The document concludes with the proposal to introduce an Agriculture Bill which will signal the UK’s departure from the Common Agricultural Policy. Chapter Fifteen says that the Agriculture Bill will be designed to meet the policy ambition set out in the consultation paper and could provide the Government with the legislative power to do any of the following:

1.) To continue making payments to farmers and land managers, with the power to amend eligibility criteria for payments.
2.) To strip out unnecessary bureaucracy and strengthen the delivery landscape.
3.) To create new schemes for one or more of the following purposes:
• promoting and increasing agricultural productivity and resilience
• preserving, protecting, and enhancing the environment
• providing support to rural communities
• animal and plant health and animal welfare
• public access
4.) To establish a new basic compliance or inspection regime.
5.) To take emergency measures to provide aid in extreme events.
6.) To retain UK-wide frameworks where we need commonality.
7.) To provide for continuity during the ‘agricultural transition’ period for some elements of the current CAP.

The final two questions in the consultation are concerned with the proposed legislation: 1) “How far do you agree with the proposed powers of the Agriculture Bill?” and 2) “What other measures might we need in the Agriculture Bill to achieve our objectives?”

The conclusion of the Executive Summary states: “We should all have an interest in the landscape around us: it must sustain us now and be held in trust for future generations. We welcome all views on our policy proposals.” Respondents have until the 8th of May 2018 to submit their views.


Photograph: Pasture, Skelton, with Carrock Fell in the background. Near Low Braithwaite, Cumbria. © Copyright Andrew Smith and licensed for reuse under this Creative Commons Licence. Health and Harmony: the future for food, farming and the environment in a Green Brexit says that “the distinctive character of the Lake District landscape has been shaped through long association with sheep farming, one of the sectors currently most dependent on Direct Payments.” The Government says that hill farmers and upland areas have the potential to benefit from new environmental land management schemes under the proposed agricultural policy for England.


[1] The plan was published on the 11th January 2018. See the ENA article: “UK Government publishes its 25 year plan for the environment”. The 25 year plan only applies to England.

[2] See the GOV.UK web page “The future for food, farming and the environment”.

[3] Health and Harmony: the future for food, farming and the environment in a Green Brexit is a PDF document available from the GOV.UK website which you can download by clicking here. The Future Farming and Environment Evidence Compendium is another PDF document which you can download from the GOV.UK website by clicking here. The annex on stakeholder proposals and the annex on Countryside Stewardship options are both available from [2] above. Note: Quotations from the consultation document have been slightly modified in certain places to correct grammatical errors in the original.

[4] Agri-environment schemes are now known as environmental land management schemes. The current environmental land management scheme is the Countryside Stewardship scheme. Defra says the Countryside Stewardship scheme supports a range of environmental benefits, including: slowing the decline in wildlife populations; tree planting; improving water quality; and providing more high-quality recreational opportunities. In conceding that the CAP has made some environmental improvements, Defra says “there is evidence that land in publicly funded agri-environment schemes can deliver benefits which outweigh the payments made.” The successes delivered by agri-environment schemes in England over the last five years include: “280,000km of maintenance, management and restoration of hedgerows, ditches and stonewalls; creating nesting and food resources to increase breeding populations of nationally scarce farmland birds and pollinators such as cirl buntings, stone curlews, and the marsh fritillary butterfly; and 19,000 hectares of planted areas providing pollen and nectar sources for pollinators (Higher Level Scheme management for pollinators can significantly increase the size of wild bumblebee populations).” In addition, a footnote says that a 2012 study on farmland bird population growth rates showed positive effects related to the management of winter food resources for a number of seed-eating species. The consultation document also includes a case study on the Hedgerows and Boundaries Grant, which is “a standalone scheme under Countryside Stewardship and is a popular approach with farmers and stakeholders. Applicants select from a range of investments such as hedgerow laying, coppicing, and restoration of dry stone walls. They create habitat and feeding areas for birds, insects and small mammals, as well as adding to the character of the local landscape. These works can have a lasting legacy for our countryside. This simple grant offer is competitive, but the scoring is easy to follow and has been agreed with stakeholders. In 2016, the first year of the grant, we funded 728 agreements with a value of £3 million. This resulted in the restoration of 45,897m of stone walls and 177,539m of hedges.”

[5] On the concept of natural capital, see the ENA article: “Assessing the Value of ‘Natural Capital'”.

[6] The consultation document states: “When ammonia is released into the air, it reacts with nitrogen oxides and sulphur dioxide and forms secondary particulate matter, which has a significant impact on human health. Most notably, ammonia contributes to smog in urban areas. In addition, when deposited on land, ammonia can cause acidification or overload soils and watercourses with nitrogen, leading to biodiversity loss in sensitive habitats.” Evidence cited in the accompanying Future Farming and Environment Evidence Compendium suggests that ammonia emissions attributable to farming constitute 83% of the UK total. In Chapter Six of the consultation paper (“Enhancing our environment”), Defra says that “we can reduce the harmful contribution agriculture makes to ammonia emissions and air quality through, for instance, encouraging the use of low emission slurry spreading equipment or supporting investment in slurry covers.” For recent research on the impact of air pollution on human health, see the ENA article: “Recent Research – The impact of air pollution on human health”.

[7] The consultation document states: “Nitrous oxide and methane greenhouse gas emissions from agriculture have fallen by around 15% since 1990, and agriculture currently contributes 10% of UK emissions. Whilst it remains incredibly important that we continue to reduce carbon emissions from the farming sector, environmental land management could play a pivotal role in responding to climate change by increasing the ability of farmland and the countryside to sequester carbon, thereby enhancing the benefits and value of our natural resources.” In Chapter Six of the consultation paper (“Enhancing our environment”), Defra says that incentivising practices that involve carbon sequestration and greenhouse gas reduction would help to tackle climate change and also improve biodiversity: “This could be achieved through support for landscape scale restoration projects, hedgerow creation and habitat management, and by continuing to support woodlands and forestry.”

[8] The case studies include tree planting and other measures to improve soil health in Nottinghamshire; selective planting to support ground-nesting farmland birds and pollinating insects in West Norfolk; wet grassland restoration in Devon; an innovative slurry-spreading system that reduces ammonia emissions in Suffolk; peat restoration in Cumbria; the creation of a new ‘National Forest’ in the Midlands; and the protection of the small-scale industrial remains of a lead mine and lime kiln in Lancashire. For the details, see pp.38-41 of the consultation document (note [3] above). See also note [4] above.

UK Government publishes its 25 year plan for the environment

Environment Secretary Michael Gove pledges to “leave our environment in a better state than we found it”

“Ambitious project” sets out goals and targets for clean air, clean water, biodiversity, conservation, waste management, land management, flood risk, the marine environment, and climate change

February 14th 2018
The UK Government has published its long-awaited 25 year plan for the environment. Its intentions to produce such a plan were first announced in October 2015, in response to a number of recommendations from the Government’s Natural Capital Committee – see the ENA article “Defra responds to recommendations of Natural Capital Committee”. The plan was finally published by Defra (the Department for the Environment, Food & Rural Affairs) on the 11th January 2018.

On its website, the Government says its 25 year plan “sets out our goals for improving the environment, within a generation, and leaving it in a better state than we found it. It details how we in government will work with communities and businesses to do this.” [1] The plan consists of a 151-page document accompanied by three appendices containing, firstly, a list of the UK’s current strategies on the environment; secondly, a list of the UK’s international agreements; and thirdly, a supplementary evidence report. A further document summarises the Government’s targets. The main document has been called a sister document to the Government’s Clean Growth Strategy, which was published last October – see the ENA article “UK Government publishes ‘The Clean Growth Strategy'”.

“Creating a better place”

In her foreword, the PM points out that the UK’s departure from the EU will mean that “control of important areas of environmental policy will return to these shores.” She continues: “We will use this opportunity to strengthen and enhance the protections our countryside, rivers, coastline and wildlife habitats enjoy, and develop new methods of agricultural and fisheries support which put the environment first.” The Environment Agency’s motto of “creating a better place” is taken up by Michael Gove in his foreword to the document: “It is this Government’s ambition to leave our environment in a better state than we found it.” He goes on to summarise the Government’s aspirations: “We need to replenish depleted soil, plant trees, support wetlands and peatlands, rid seas and rivers of rubbish, reduce greenhouse gas emissions, cleanse the air of pollutants, develop cleaner, sustainable energy, and protect threatened species and habitats.”

The scope of the Government’s 25 year plan covers all aspects of the environment. The introduction sets out its 25-year goals and includes an ambitious list of targets. “Using the natural capital framework set out by the Natural Capital Committee,” it says, “we have framed our goals for environmental improvement over the next 25 years around six primary goods and benefits offered by a healthy environment.” By adopting the Plan, the Government says, “we will achieve clean air; clean and plentiful water; thriving plants and wildlife; a reduced risk of harm from environmental hazards such as flooding and drought;” and “enhanced beauty, heritage, and engagement with the natural environment.” The sixth benefit it wants to achieve is a more sustainable and more efficient use of natural resources. The Government also says it will manage pressures on the environment by mitigating and adapting to climate change; minimising waste; managing exposure to chemicals; and enhancing biosecurity.

Goals and targets: Clean air, clean water

The introduction also sets out the means by which these goals will be achieved. For example, on clean air, the Government says it will achieve this by, firstly, meeting legally binding targets to reduce emissions of five damaging air pollutants, which “should halve the effects of air pollution on health by 2030;” secondly, by ending the sale of new conventional petrol and diesel cars and vans by 2040; and thirdly, by “maintaining the continuous improvement in industrial emissions by building on existing good practice and the successful regulatory framework.”

On clean and plentiful water, the Plan sets out four measures by which this goal will be achieved. The goal here is to improve “at least three quarters of our waters to be close to their natural state as soon as is practicable.” ‘Waters’ includes rivers, lakes, groundwater aquifers, estuaries and coastal waters, and the Plan says that the 75% target reflects the costs and benefits analysis provided by the current River Basin Management Plans. The ‘natural states’ of such waters are set out in international benchmarks and defined in statutory guidance to the Environment Agency, the body responsible for developing the River Basin Management Plans in consultation with local partners.

The first measure concerns water abstraction. The Plan seeks to reduce “the damaging abstraction of water from rivers and groundwater, ensuring that by 2021 the proportion of water bodies with enough water to support environmental standards increases from 82% to 90% for surface water bodies and from 72% to 77% for groundwater bodies.” The second measure concerns specially protected areas. The Plan aims to reach or exceed objectives “for rivers, lakes, coastal and ground waters that are specially protected, whether for biodiversity or drinking water as per our River Basin Management Plans.” The third measure concerns water companies and leakages. The Government says it supports OFWAT’s ambitions on leakage, “minimising the amount of water lost through leakage year on year, with water companies expected to reduce leakage by at least an average of 15% by 2025.” On recreational waters, the Plan seeks to minimise by 2030 “the harmful bacteria in our designated bathing waters.” The Government says it will continue improvements “to the cleanliness of our waters,” whilst ensuring that potential bathers are warned of any short-term pollution risks.

Goals and targets: “Thriving plants and wildlife”

On biodiversity, the Government makes the following pledge: “We will achieve a growing and resilient network of land, water and sea that is richer in plants and wildlife.” Three specific goals are concerned with threatened species, habitat, and woodland, including “taking action to recover threatened, iconic, or economically important species of animals, plants and fungi (such as bees and other pollinating insects), and where possible to prevent human-induced extinction or loss of known threatened species in England and the Overseas Territories.” On habitat, the goal is to create or restore 500,000 hectares of wildlife-rich habitat outside the protected site network, “focusing on priority habitats as part of a wider set of land management changes providing extensive benefits.” Priority habitats are defined as “habitats of principal importance under the Natural Environment and Rural Communities Act.” The Plan says that more detailed targets for the restoration and creation of protected or priority habitats will be developed “as part of our post 2020 strategy for nature.” On woodland, the Plan reiterates the Government’s aspiration to increase woodland cover in England to 12% by 2060, which would involve planting 180,000 hectares by the end of 2042.

On freshwater, the goal is to restore “75% of our one million hectares of terrestrial and freshwater protected sites to favourable condition, securing their wildlife value for the long term.” On the marine environment, the Plan sets out four general goals. The first is to reverse the loss of marine biodiversity and to restore it “where practicable.” The second is to increase the proportion of “protected and well-managed seas,” and to better manage existing protected sites. The third is to ensure that populations of key species are “sustainable with appropriate age structures,” and the fourth is to ensure that “seafloor habitats are productive and sufficiently extensive to support healthy, sustainable ecosystems.” The Plan includes specific targets for reducing marine pollution, as explained below.

In addition to the “six primary goods and benefits offered by a healthy environment,” the Plan also recognizes the need to manage the environmental pressures that are the results of human actions. Such pressures include biosecurity and the risks presented by invasive species – see the ENA article “Invasive Species – New laws and new initiatives”. The Plan pledges to enhance biosecurity “to protect our wildlife and livestock, and boost the resilience of plants and trees.” The goals here include “managing and reducing the impact of existing plant and animal diseases, lowering the risk of new ones and tackling invasive non-native species, working with industry to reduce the impact of endemic disease” and “reaching the detailed goals to be set out in the Tree Health Resilience Plan of 2018.” Looking ahead, the goals also include “ensuring strong biosecurity protection at our borders, drawing on the opportunities leaving the EU provides.”

Goals and targets: Flooding and drought

On flooding, drought and coastal erosion, the introduction sets out a wish list of aspirations that “will reduce the risk of harm to people, the environment and the economy from natural hazards.” The goals cover access to information, collaboration in risk management, planning for development, planning for drought, and boosting resilience. The actions are summarized as follows:

• ensuring that people “are able to access the information they need to assess any risks to their lives and livelihoods, health and prosperity posed by flooding and coastal erosion;”
• “bringing the public, private and third sectors together to work with communities and individuals to reduce the risk of harm;”
• “making sure that decisions on land use, including development, reflect the level of current and future flood risk;”
• “ensuring interruptions to water supplies are minimised during prolonged dry weather and drought;” and
• “boosting the long-term resilience of our homes, businesses and infrastructure.”

Goals and targets: Conservation and engagement with the natural environment

The Plan pledges to “conserve and enhance the beauty of our natural environment, and make sure it can be enjoyed, used by, and cared for by everyone.” The goals cover conservation, accessibility to green spaces, and social engagement, with the actions summarised as follows:

• “safeguarding and enhancing the beauty of our natural scenery and improving its environmental value while being sensitive to considerations of its heritage;”
• ensuring that there are “high quality, accessible, natural spaces close to where people live and work, particularly in urban areas,” and “encouraging more people to spend time in them to benefit their health and well-being;” and
• “focusing on increasing action to improve the environment from all sectors of society.”

Goals and targets: Resources and sustainability

The Government says it will ensure that natural resources are used more sustainably and efficiently, and that food is produced profitably as well as sustainably. It wants to increase the long-term supply of English-grown timber by supporting larger scale woodland creation. It also wants to ensure that “all fish stocks are recovered to and maintained at levels that can produce their maximum sustainable yield.” As for specific targets, the Plan proposes to “maximise the value and benefits we get from our resources, doubling resource productivity by 2050.” Resource productivity is defined as a measure of the value (in terms of GDP) “we generate per unit of raw materials we use in the economy.” The Government also says it wants to see improvements in approaches to soil management, with the aspiration that by 2030 “all of England’s soils will be managed sustainably.” It plans to use “natural capital thinking” to develop appropriate soil metrics and management approaches. [2]

Achieving the goals

Having set out the Government’s 25-year goals and targets in the introduction, the Plan moves on to discuss the specific plans, proposals and activities that will achieve these aims. Section One of the document contains chapters on six key areas identified by the Government as the foci for action, as follows:

• “using and managing land sustainably,”
• “recovering nature and enhancing the beauty of landscapes,”
• “connecting people with the environment to improve health and wellbeing,”
• “increasing resource efficiency and reducing pollution and waste,”
• “securing clean, healthy, productive and biologically diverse seas and oceans,” and
• “protecting and improving our global environment.”

Sustainable land management

Moving on to details, Chapter One outlines proposals under the general heading of managing land sustainably. These cover five areas: development, farming, soil, woodland, and flood risk. On development, the Plan talks about “embedding an ‘environmental net gain’ principle for development, including housing and infrastructure.” On farming, the Plan sets out ways of “improving how we manage and incentivise land management.” These include the design and delivery of a new environmental land management system; introducing new farming rules for water abstraction; working with farmers to use fertilisers efficiently; and “protecting crops while reducing the environmental impact of pesticides.” On soil, under the general heading of “improving soil health and restoring and protecting our peatlands,” the Government wants to develop better information on soil health and to restore vulnerable peatlands, with the goal of ending peat use in horticultural products by 2030. On woodland, under the general heading of “maximising its many benefits,” the Plan expresses support for larger scale woodland creation, including the development of a new “Northern Forest,” and proposes to appoint a national “Tree Champion.” Finally, on flood risk and coastal erosion, the Government plans to expand the use of natural flood management solutions, to put in place more sustainable drainage systems, and to make ‘at-risk’ properties more resilient to flooding.

“Recovering nature”

Chapter Two is devoted to plans for “recovering nature and enhancing the beauty of landscapes.” These cover three areas. The first is nature protection and recovery, which lists five aims, the first of which, “publishing a strategy for nature,” is currently a plan to produce a plan. Further aims are as follows: developing a “Nature Recovery Network”; providing opportunities for the reintroduction of native species; “exploring how to give individuals the chance to deliver lasting conservation”; and “improving biosecurity to protect and conserve nature”. The second area is the conservation and enhancement of natural beauty, and here the Government proposes to conduct a review of National Parks and AONBs (Areas of Outstanding Natural Beauty). The third area is “respecting nature in how we use water,” and here the plans overlap with the plans to reform farming, mentioned above. As well as “reforming our approach to water abstraction,” the Government wants to increase water supply and to provide incentives for greater water efficiency and less personal use.

“Connecting people with the environment”

The plans in Chapter Three focus on the health benefits of connecting people with the environment. These cover four areas. The first is titled “helping people improve their health and wellbeing by using green spaces.” Here, as well as the general aim of promoting the health benefits of the natural environment, the Plan sets out a specific aim of “considering how environmental therapies could be delivered through mental health services.” The second area is children, which encompasses the general aim of “encouraging children to be close to nature, in and out of school.” The Government wants to help primary schools create nature-friendly grounds, and to support “more pupil contact with local natural spaces.” The third area is “greening our towns and cities,” and the aims here are to create more green infrastructure and to plant more trees in and around towns and cities. The fourth area is a campaign “to see more people from all backgrounds involved in projects to improve the natural world.” The Government says it will make 2019 a year of action for the environment, “putting children and young people at its heart,” and helping them to engage with nature. The Year of Green Action “will provide a focal-point for organisations that run environmental projects, and will encourage wider participation.”

Minimising waste and reducing pollution

Chapter Four includes plans to increase resource efficiency, reduce waste, and reduce pollution. As regards waste management, the overriding aim is to maximise resource efficiency and to minimise the environmental impacts when a resource reaches its “end of life”. Here, one of the Government’s specific targets is to achieve “zero avoidable plastic waste by the end of 2042,” with ‘avoidable’ defined in the introduction as “what is Technically, Environmentally and Economically Practicable.” The introduction also states that the Government “will work towards our ambition of zero avoidable waste by 2050” (i.e., all waste including plastic waste), with the goal of “significantly reducing and where possible preventing all kinds of marine plastic pollution – in particular material that came originally from land.” The Government also pledges to meet all existing waste targets, “including those on landfill, reuse and recycling,” and to develop “ambitious new future targets and milestones.” Further aims are to reduce food supply chain emissions and waste; to improve the management of residual waste; to reduce litter and littering; to crack down on fly-tippers and waste criminals; and to reduce the impact of wastewater. The introduction specifies the target of “seeking to eliminate waste crime and illegal waste sites over the lifetime of this Plan, prioritising those of highest risk,” whilst also “delivering a substantial reduction in litter and littering behaviour.”

Moving on to pollution, two of the plans here are aspirations. These are the intentions to publish a Clean Air Strategy and to publish a Chemicals Strategy. Further plans to reduce pollution consist of curbing emissions from combustion plants and generators, “minimising the risk of chemical contamination in our water,” and “ensuring we continue to maintain clean recreational waters and warning about temporary pollution.” In the introduction, the Government says it will ensure that “chemicals are safely used and managed” and that “the levels of harmful chemicals entering the environment (including through agriculture) are significantly reduced.” Four specific targets are set out here, with the Government stating it will achieve these ambitions by:

• “seeking in particular to eliminate the use of Polychlorinated Biphenyls (PCBs) by 2025, in line with our commitments under the Stockholm Convention;”
• “reducing land-based emissions of mercury to air and water by 50% by 2030;”
• “substantially increasing the amount of Persistent Organic Pollutants (POPs) material being destroyed or irreversibly transformed by 2030, to make sure there are negligible emissions to the environment;” and
• “fulfilling our commitments under the Stockholm Convention as outlined in the UK’s most recent National Implementation Plan.”

The marine environment

The maintenance of unpolluted waters overlaps with Chapter Five and the marine environment, where the overriding aim is to secure “clean, healthy, productive and biologically diverse seas and oceans.” The main plan here is to introduce a sustainable fisheries policy “as we leave the Common Fisheries Policy.” The policy will aim to achieve “good environmental status in our seas while allowing marine industries to thrive.” As mentioned above, the Government says it will work towards the elimination of all avoidable waste by 2050, and the elimination of avoidable plastic waste by the end of 2042, with the goal of “significantly reducing and where possible preventing all kinds of marine plastic pollution – in particular material that came originally from land.”

Climate change and the global environment

Under the general heading of “protecting and improving our global environment” in Chapter Six, the Plan singles out three areas for specific focus. The first is “providing international leadership and leading by example” – firstly by tackling climate change, and secondly by protecting and improving international biodiversity. The second area is “helping developing nations protect and improve the environment” – firstly by providing assistance and supporting disaster planning, and secondly by supporting and protecting international forests and sustainable global agriculture. The third area is titled “leaving a lighter footprint on the global environment.” The aims here are to enhance sustainability, to protect and manage risks from hazards, and to support zero-deforestation supply chains.

In the introduction, the Government says it will take “all possible action to mitigate climate change, while adapting to reduce its impact.” Three commitments are set out here: firstly, “to continue to cut greenhouse gas emissions including from land use, land use change, the agriculture and waste sectors, and the use of fluorinated gases;” secondly, “to ensure that all policies, programmes, and investment decisions take into account the possible extent of climate change this century;” and thirdly, “to implement a sustainable and effective second National Adaptation Programme.” As for specific targets, the Government says that “the UK Climate Change Act 2008 commits us to reducing total greenhouse gas emissions by at least 80% by 2050 when compared to 1990 levels.”

“Putting the Plan into practice”

Section Two of the document is titled “Putting the Plan into practice”. On general principles, the Government says it will consult on “setting up a new independent body to hold government to account and a new set of environmental principles to underpin policy-making.” The Plan also sets out the following commitments:

• “to develop a set of metrics to assess progress towards our 25-year goals;”
• “to refresh the 25 Year Environment Plan regularly to ensure that collectively we are focusing on the right priorities, using the latest evidence, and delivering better value for money;”
• “to strengthen leadership and delivery through better local planning, more effective partnerships, and learning from our four pioneer projects;” [3]
• “to establish a new green business council and explore the potential for a natural environment impact fund;” and
• “to work closely with a large range of stakeholders over the coming year to identify their contribution to the goals set out in this Plan.”

In the introduction to the Plan, the Government states: “This Plan is a living blueprint for the environment covering the next quarter of a century. It is an ambitious project, made even more so by our use of a natural capital approach, a world first.” However, with the Government currently embroiled in the aftermath of the EU referendum, achieving these ambitions may not be very high on its list of priorities.


Photograph: Braunton Burrows, North Devon. © Copyright Lewis Clarke and licensed for reuse under this Creative Commons Licence. The caption says: “Braunton Burrows is designated nationally and internationally for its biodiversity, being an SSSI, Special Area of Conservation (SAC), and a UNESCO Biosphere Reserve.” This reserve is the location for one of the Government’s four pioneer projects, in this case demonstrating the applicability of a natural capital approach to the coastal environment.


[1] A Green Future: Our 25 Year Plan to Improve the Environment, available as a PDF document from GOV.UK publications.
[2] On the concept of natural capital, see the ENA article “Assessing the Value of ‘Natural Capital'”.
[3] The four pioneer projects are: the Cumbria Catchment Pioneer, led by the Environment Agency (using a natural capital approach to the management of river catchments); the North Devon Landscape Pioneer, led by Natural England (the use of natural capital in determining environmental priorities in the North Devon UNESCO Biosphere Reserve); the Greater Manchester Urban Pioneer, led by the Environment Agency (the use of environmental enhancements in improving well-being); and the Marine Pioneer, led by the Marine Management Organisation (applying a natural capital approach to the marine environment, based on a study of two separate coastal areas – the North Devon Biosphere Reserve and the Suffolk Coasts and Heaths AONB). The four pioneer projects started in 2016.