We welcome the opportunity to respond to the consultation on environmental targets. Along with the 25 Year Environment Plan (Environmental Improvement Plan), existing targets and other measures in the Environment Act, the proposed targets provide a good platform from which to make progress towards the government’s long-term environmental goals.
We welcome the government’s ambition for a cleaner and more resilient water environment. The proposed targets will tackle some of the major pressures impacting on the water environment including agriculture, wastewater, abandoned metal mines and water demand. A healthy water environment is essential for people, nature, farming and industry.
The proposed targets for water will complement existing targets by driving action to address some of the main pressures preventing the achievement of good ecological status. They will support and mutually reinforce existing targets. These include the outcome-based targets in the form of the 5,000 locally specific water body objectives in River Basin Management Plans (RBMPs) and the 25 Year Environment Plan target to improve at least three quarters of England’s waters to be close to their natural state as soon as is practicable. We are currently reviewing the water body objectives in the RBMPs and will support government in any future review of the outcome targets in the 25 Year Environment Plan.
We support the targets to help address the biggest sources of nutrient pollution. The complementary agriculture and wastewater elements of the nutrient target will ensure that both sectors contributing the most nutrient pollution play a role in addressing the issue.
Nutrient target – wastewater
Over the last 2 decades, phosphorus in wastewater discharged into rivers has reduced by 67%. However, monitoring shows that there is still far too much phosphorus entering the water environment. Water companies are still the largest source of this nutrient pollution.
The focus on phosphorus from wastewater is correct as the nutrient impacts on freshwater ecology are being driven primarily by phosphorus. This target needs to provide the water industry with the flexibility to deliver the reduction in phosphorus by using mainly biological treatment and nature-based solutions.
This target will complement action to tackle storm overflows. The Environment Agency supports the ambitious targets outlined in the consultation on a plan to reduce storm overflows discharges.
Nutrient target – agriculture
Agricultural practices are one of the most significant sources of water pollution and are responsible for around 40% of water bodies failing to achieve our ambition for being in a near natural state. In England, agriculture accounts for: 50% to 60% of nitrate, 75% of sediment, 75% of pesticides, and 20% to 30% of phosphorus in the water environment. Increased action to address this issue is essential to improve water quality and support the government’s ambitions for clean and plentiful water and biodiversity.
We strongly support the action-based target to reduce nutrient and sediment pollution from agriculture. Its achievement will require government policies to drive changes in farming practice. To deliver this target we would like to see the government continuing to enable the adoption of regulatory and incentivised voluntary land management measures and land use change. Of particular importance will be the three new environmental land management schemes and initiatives to drive private investment, such as nature for carbon. We also support the move to secure improvements through greater efficiency in the food chain, an increase in industry-led schemes and technological improvements.
The inclusion of both sediments and nutrients within this target is essential. Excess sediment impacts on aquatic life in rivers, from algae to fish. Sediments destroy the habitat where wildlife lives and breeds, transport other pollutants and disrupt biological processes. They also decrease farm productivity through the loss of valuable soil.
Abandoned metal mines
We support the government’s commitment to tackle pollution from abandoned metal mines and address this legacy of Britain’s industrial revolution. Pollution from metal mines causes localised but serious pollution in up to 1,500km of English rivers and estuaries, harming fish, invertebrates and ecosystems. Half the metals in surface waters come from these mines, as much as is discharged by all regulated industries combined.
The impacts are concentrated in disadvantaged rural communities in northern and south-west England. The pollution also causes adverse economic impacts on jobs and tourism that rely on clean water environments. These mines were abandoned (long) before 2000 and so the former operators are not liable for the long-term environmental impacts. Thus, it falls to government to act.
Water demand target
There is much environmental value in a statutory target to maintain the focus on reducing the use of public water supplies. This will underpin progress with reducing the demand for water, protect the environment, improve resilience to extreme events, and help address climate change. The target will complement water industry planning and drive action. We recognise the value of including the non-household sector within the target.
We support the policies set out in the Written Ministerial Statement on reducing demand for water (1 July 2021) that will help achieve the target. These include a water efficiency label for water using products, water efficient homes, and a consistent approach to leaks from customers’ own supply pipes.
Water companies, regional groups and other government departments all have an important part in supporting delivery of this target. Businesses and water retailers will also be essential to ensuring that the target is achieved. We will work with these groups to enable the demand measures required to be planned and achieved through the various planning processes. We will monitor delivery against this target.
Links between the water and biodiversity targets
We need our rivers, canals, lakes, estuaries, coastal waters and groundwaters to be of the right quality and flow level to meet the health, business and leisure needs of society, while underpinning ecosystems on which the whole environment and nature recovery relies.
Long-term species targets
We welcome the inclusion of statutory targets to halt and reverse the decline in species abundance and improve the extinction risk index for rare and threatened species. This will drive specific action on species recovery and will support the development of clear direction, focus and action to recover species and reverse decline. We are pleased to see recognition of the importance of restoring a range of habitats and reducing adverse pressures in achieving these targets. We support the intention to deliver an integrated approach across the suite of environmental targets; this is essential. Whilst recognising the importance of halting the decline in species population sizes as an initial focus, ideally, we would welcome the increase in species abundance to be baselined to 2022 rather than 2030 as proposed in the consultation.
We recognise the value of using long-term robust data sets to measure progress and track changes in species abundance, supported by continuing data gathering and monitoring frameworks. These data sets represent a broad range of habitats and acts as a reasonable proxy for the abundance of species in England. We welcome the inclusion of datasets which represent the wetland and water dependent environment, and the opportunity to build and strengthen this suite of data over time. Ideally, additional datasets and supporting information should be considered to enable an informed and targeted response to species recovery.
The Environment Agency has been operating a fish monitoring programme since 2000 specially designed to determine spatial and temporal changes in abundance of key riverine fish populations. In addition, we have data available on salmon abundance in all of the principal salmon rivers in England and Wales. These data will provide a valuable and different metric when looking at species abundance, based on an element of the environment that resonates well with the public. Fish are impacted by multiple pressures and as such are an excellent indicator of all round river health.
Long-term wider habitats target
We are pleased to see the long-term wider habitat target to create and restore additional wildlife-rich habitat outside of protected sites and that the target ambition asks for delivery in excess of 500,000 hectares. This statutory target will drive much-needed action on a wider catchment and landscape scale, providing the opportunity to create more, bigger, better and more joined up wildlife rich habitat networks. Creating and improving wildlife-rich habitat networks and sites will buffer and have positive impacts on Protected Sites features and underpin the species abundance targets by allowing a wider range of species to spread and thrive. Ideally, we would welcome a higher level of ambition, as the creation or restoration of 500,000 hectares sets a moderate level of ambition in how we manage and improve the environment to halt the decline in biodiversity and to support nature recovery. Delivering this target will also provide opportunities for people to connect with and enjoy nature and obtain health benefits from that interaction.
The recognition of the importance of wetland and water dependent biodiversity through the inclusion of freshwater, estuarine and coastal habitats within this target is important. Aquatic habitats are amongst our most valuable natural assets, and they play a key role in supporting and connecting wildlife and nature recovery within the landscape. This target, in combination with the wider suite of environmental targets proposed, will help to drive the step change needed to redress the significant loss and decline of habitats and species in the aquatic environment and reduce wider catchment pressures which adversely impact on them, with wider benefits. For example, England’s saltmarshes are estimated to sequester more than 200,000 tonnes of carbon each year: equivalent to emissions from nearly 40,000 households.
Terrestrial Protected Sites target
We welcome the continued commitment to recovering the condition of terrestrial (including water and water dependent) Protected Sites as they support significant biodiversity and represent the core ecological basis for nature recovery. Improving the condition of these sites will be critical in supporting the proposed species abundance and extinction risk targets, and connectivity within the wider wildlife-rich habitat networks. We welcome the proposal to set a protected sites target following the review of protections through the nature recovery green paper consultation that would support the delivery of the 25 Year Environment Plan goals.
Target proposals for biodiversity in the sea
We welcome the target proposal for biodiversity at sea for 70% of the designated features in the Marine Protected Areas (MPA) network to be in favourable condition and the remainder in recovering condition by 2042. We believe this target sets a reasonable level of ambition to drive action to reduce the impact of potentially damaging activities, manage MPAs effectively and improve the MPA network’s condition. We recognise the importance of additional reporting on changes in individual feature condition. We welcome the opportunity to work with Defra to ensure the monitoring programmes provide sufficient evidence to enable the target to be reached.
Air Quality targets
We support the new ‘ambient concentration’ and ‘population exposure reduction’ targets for PM2.5. We will continue to support the development of interim targets and the approach to implementation which aim to bring concentration levels down as quickly as possible. We welcome the development of a population exposure reduction target which will minimise the impact on communities and help reduce inequalities.
We support the residual waste target and have supported Defra in developing the target and designing the indicator. We continue to work with Defra on the design of interim targets and will continue to provide the data required to track progress against the target. We will support future refinement once waste tracking is delivered as well as providing input to the development of a resource efficiency target.
We recognise that the proposed target will be challenging to meet, and we look forward to working with Defra to identify new policy initiatives, interventions and regulatory approaches that will move us towards a more circular economy.
The Environment Agency supports these ground-breaking targets while recognising that delivery will need sufficient resources, public and private. We will continue to maximise delivery within existing resources and look forward to working with Defra on developing the approach to implementation. As a key delivery body, we are keen to work collaboratively with Defra to fully define our role in delivering the targets and the relevant accountabilities, responsibilities and resource implications.