National Trust publishes response to 25 Year Environment Plan

Over a month has passed since the publication of the Government’s new 25 Year Environment Plan. We’ve had time to further digest its contents and today we’re publishing our detailed response, which you can see here (you can still read our initial response on the day of its publication here). We’ve shared our analysis with the Environmental Audit Committee as part of their inquiry on the Plan.

As an organisation that manages 247,000 hectares of land and over 775 miles of coastline, the National Trust can bring a lot to the table in supporting Government’s implementation of the Plan and in trialling some of the proposed new approaches on the land we look after. We’ve written to the Secretary of State Michael Gove today to extend this offer of help.

A view of the coastline from Constantine Bay looking toward Trevose Head, Cornwall. ©National Trust Images/John Miller

For the Plan to truly deliver the outcomes that the environment badly needs, three key tests will need to be met:

  • will the right legal institutions and frameworks be put in place around the Plan’s goals and targets?
  • will the Government begin putting the Plan into action soon?
  • are the Plan’s goals and targets ambitious enough?

The Plan’s aspirations need legal backing

If the Plan is to deliver for nature and the historic environment, then it will need strong legal frameworks and institutions alongside it (particularly as the UK leaves behind the body of environmental law that applies to us through the EU and its institutions). This will be crucial to ensuring long-term action for the environment in the UK and that future governments are held to account. The Government has promised consultations on a new world-leading environmental regulatory body and on environmental principles.

Alongside this, we’re working with other organisations on the idea of an Environment Act, to give the Plan and its targets legal underpinning. This could be loosely modelled on the Climate Change Act, which has helped to oblige Governments of all stripes to meet legally binding emissions reduction targets, as well as giving legal powers to the independent Committee on Climate Change.

Government needs to begin enacting the Plan now

Scientific evidence tells us that there is no time to lose in delivering the environmental aims the Plan sets out. Therefore, we hope that Government is already working away behind the scenes and will begin to put the Plan into action in the coming weeks.

Yesterday, a new consultation on the future for food, farming and the environment was published by Defra, which we’ll be looking at in more detail in the coming days. The Government will soon be publishing a revised National Planning Policy Framework and that will be an important test of some of its aspirations to strengthen environmental protection in the planning process.

Highland cattle conservation grazing above the village of Malham, Yorkshire Dales National Park ©National Trust Images/Paul Harris

But we are concerned that without sustained effort across government, there is a risk that the Plan could fail. We believe that a Cabinet Sub-Committee on the Environment would help keep this issue at the top of the agenda right across Whitehall and ensure Ministers right across Government are regularly held to account for delivering it.

The Plan refers to a number of reviews and consultations that it will launch in the coming months and years. It also refers to designing a new set of environmental metrics, which will be fundamental to measuring progress. We hope that the Government can set out a timetable for these processes as soon as possible.

Good ambition but more detail needed

There is much to welcome in terms of the Plan’s contents and aspirations. Some of the targets need more detail on how they will be achieved while others seem to simply restate existing commitments from other strategies and plans. For a detailed analysis, see below (or for even more detail see our extended response here):

  • A mandatory ‘net gain’ approach for development could deliver significant environmental benefits, but it must be very carefully designed, and ensure that developers still have to avoid or mitigate harm to nature. However, one environmental benefit should not be traded off with another, which could potentially lead to adverse impacts on biodiversity.
  • We welcome moves to enhance the planning system to strengthen protections for the Green Belt, ancient woodlands and other areas. The revised National Planning Policy Framework will be a key test of Government’s commitment to this aim. Furthermore, planning departments in local authorities need to be properly resourced if they are to achieve this, but research shows that their budgets have been slashed in recent years.
  • One of the most important elements of the Plan is the new environmental land management scheme it proposes, which will in time replace the existing system of EU funding that farmers and other land managers receive. We’re concerned that the timeline for transitioning to a new scheme is too drawn out and would like to see this accelerated. We’re also calling for an independent assessment of the finances needed to deliver environmental outcomes. The National Trust has undertaken analysis with the RSPB and The Wildlife Trusts and found that the overall size of the pot of money must not be reduced even as funding is refocussed on environmental outcomes. We’re also working with Green Alliance and other partners to develop and test new economic models for sustainable land management to support the natural environment, as demonstrated through our work on Natural Infrastructure Schemes. National Trust has a unique role in protecting both our natural and cultural heritage: in any future scheme the historic and natural environments should be put on an equal footing. Since the Plan’s publication, Michael Gove has given a speech to the annual conference of the NFU Farming Conference. He confirmed that one of Government’s main aims with a new scheme for funding land management and agriculture remains to direct public funding towards public goods, primarily positive environmental outcomes. One of the main tests of this intention was yesterday’s consultation launch, which will lead to a new Agriculture Bill later this year.  We were pleased to see that the consultation paper contains several ideas outlined in our joint Wildlife and Countryside Link proposal for a sustainable land management and farming policy for England.
  • A new Nature Recovery Network of 500,000 hectares is a very welcome aspiration. With the National Trust’s commitment to create or restore 25,000 hectares of habitat by 2025, we believe we can play a role in delivering this. However, we would welcome further clarity from the Government on whether its existing target of 200,000 hectares of habitat under Biodiversity 2020 is part of this new goal (and only just over a quarter of that has been delivered so far).
  • We welcome plans for woodland creation, including the Northern Forest, and commitments to work with stakeholders in the Cumbria catchment. However, this should not detract from the need to plant trees elsewhere in the country. Woodland can help to improve our environment in many places and a strategic policy framework for achieving this would be welcome to build on commitments in the Plan.
  • In its forthcoming update of its Flood and Coastal Erosion Risk Strategy we hope that Government will put more funding and emphasis behind exploring the benefits of Natural Flood Management schemes which can provide environmental outcomes as well as mitigating erosion and flooding. Flooding and coastal erosion are a critical threat to the integrity of many National Trust places, as well as to other parts of the country.  Our Shifting Shores report outlines how we’re adapting to the challenges facing our own places.
  • We would like to work with Government to explore the use of conservation covenants which we believe could provide important funding for environmental outcomes.
  • Over half of National Trust land lies within National Parks. A new review of the role of Areas of Outstanding Natural Beauty and National Parks could help them to deliver more and better environmental outcomes.
  • The National Trust has substantial experience in connecting people (particularly children and young people) with nature and the outdoors and we hope to bring this to bear in the Government’s proposed 2019 Year of Green Action. For instance, over 400,000 children visit National Trust properties every year with an educational group, over 97,000 children have used our ’50 Things’ app to get them outdoors, and our Green Academies project encourages and skills up young people to become ambassadors for nature in their local area. We view the Plan as an opportunity to champion how access and participation in the great outdoors can enrich and transform people’s lives, as well as bring communities together.
  • Plans to improve and increase green spaces in urban areas are welcome. If these are to succeed then new financing and management models will be needed, and conservation covenants could play a role. The National Trust has significant experience in this area, such as the creation of our Future Parks Toolkit, based on our joint work on finding a sustainable future for the funding and management of public parks. We also recently supported the creation of a natural capital account for London’s green spaces, along with Heritage Lottery Fund and the Mayor of London; and are providing advice to Newcastle City Council as they create a Parks Trust to look after the city’s parks.
  • We look after 775 miles of coastline and plastic waste poses a serious threat to the beauty and biodiversity of these areas. The Government’s plans to tackle plastic waste are welcome, but will be too little too late. The aim to phase out all avoidable plastic waste by 2042 must be accelerated.
  • We believe that the Government should be as ambitious on sea as it is on land. The commitment to restore 75% of terrestrial and freshwater protected sites to favourable condition is welcome, but a similar target should be introduced for the marine environment.
  • We welcome the emphasis on the UK’s global role beyond the European Union. If the Government’s starts delivering its Plan soon then the UK has the opportunity to attend the landmark 2020 Convention on Biological Diversity meeting in China with a significant amount of political credibility in the bank.

We’ll continue to post our thoughts as the implementation of the 25 Year Environment Plan takes shape.  Meanwhile, if you’d like to know more about our views – take a look at our website – https://www.nationaltrust.org.uk/our-views

Blog by Matt Williams, Public Policy Officer, National Trust.

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