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25-Year Environment Plan – a climate change perspective

The long-awaited 25-Year Environment Plan has been published, setting out the Government’s ambitions for enhancing the natural environment over the coming decades. Kathryn Brown provides an initial look at the Plan’s coverage of climate change, and whether it contains sufficient substance.

You can read the 25-Year Environment Plan as a series of numbers. Ten goals. Six policy areas. Seven announcements of new strategies. Forty-four success criteria. One of three complementary strategies (the others being the Industrial Strategy and Clean Growth Strategy). The Plan contains an impressive array of high level statements on the desire for a better, bigger, more joined up natural environment. But underneath the rhetoric, what are the priorities, and is there substance behind the numbers?

On an initial look, here are my thoughts:

  1. Climate change is front and centre

Of the ten goals, mitigating and adapting to climate change is goal seven. Climate change is mentioned in both of the forewords by the Prime Minister and the Secretary of State for the Environment, Michael Gove. There is recognition of climate change being “still perhaps the most serious long-term risk to the environment”. On mitigation (i.e. reducing greenhouse gas emissions) the document mainly steers the reader back to the recently published Clean Growth Strategy. We will be publishing our assessment of that strategy on 17 January. On adapting to climate change the Plan states, “we will do whatever is necessary to adapt to the effects of a changing climate.”

It’s good to see that climate change has a dedicated section in the Plan, but also that it is mentioned throughout the document. This cross-cutting approach is heartening, both because the Plan is being given an equal footing alongside the Clean Growth Strategy, and because it is only through reducing other pressures on the natural environment that we will enable it – as far as possible – to adapt. To meet the challenges of climate change, all of the goals in the Plan will need to be met.

  1. The priority areas for action on climate change adaptation are covered

In a previous blog on how to measure success on adaptation in the natural environment, I outlined the four areas that the ASC has said need to be improved in order to give us the best chance of adapting to climate change. These four areas are: resilience of habitats and biodiversity; soil health; flood hazard protection; and the marine environment and fisheries. Each area is covered in some detail in the Plan. It contains announcements for new strategies on nature, peatlands, fisheries, and of course the next National Adaptation Programme. And there are a range of relevant actions included, such as accelerated woodland planting (including the creation of the new Northern Forest), developing a 500,000 hectare nature recovery network, and investing £200,000 to identify better ways to monitor soil health, including soil carbon. These measures are important for both climate change mitigation and adaptation.

The Plan also includes ambitions for using the natural environment to improve societal health. The strengthening of an “environmental gain principle” for new development, if implemented well, could incentivise much greater uptake of green infrastructure including sustainable urban drainage (SuDS), green space, green roofs and walls. These are measures that help to reduce the risk to people from flooding and overheating, and also have a host of co-benefits, for example in increasing urban habitat space for biodiversity, and improving air quality. The Plan includes actions to amend Planning Practice Guidance to clarify construction and maintenance arrangements for sustainable urban drainage, which the ASC and many other organisations have called for. There is also an action to look at strengthening the National Planning Policy Framework to ensure new developments are flood resilient.

  1. BUT… how success will be measured remains to be seen

The main gaps in the Plan relate to its success criteria. These might be regarded as points of detail, but they are crucial. Out of 44 success criteria in the Plan, only 11 are SMART – i.e. they are specific and contain both a quantified action and a date for completion. As currently set out, these success criteria only go a small way to explaining how the actions set out in the Plan will serve to meet the goals.

For example, to achieve the goal of thriving plants and wildlife, there are targets to restore 75% of terrestrial and freshwater protected sites to a favourable condition. This is an important adaptation goal, and is more ambitious than what’s currently set out in the Government’s Biodiversity 2020 strategy – but there is no deadline. Without a deadline it is hard to know when this target might be met or how to measure progress. There are also notable gaps on targets for species recovery. And a significant proportion of the success criteria are vague, for example, “ensuring that food is produced sustainably and profitably.” As written in the Plan, it is not possible to measure progress towards these objectives.

All in all, the Plan is more of a strategy (‘this is our intent’), and less of a plan (‘this is how we will get there’). Nonetheless, the inclusion of at least some specifics, a sense that the natural environment is being given real importance, a focus on achieving a net gain in natural capital, and the prominence of both climate change mitigation and adaptation are causes for optimism. More attention is now needed on the specifics (the how, when, and who questions), to flesh out how the Plan can succeed in addressing the risks from climate change – through mitigation and adaptation – and improve our natural environment more generally.

Kathryn Brown is Head of the CCC’s Adaptation Sub-Committee Secretariat.