The countdown has begun… [updated]

June 9, 2021

With five months to go before the most important wildlife summit in history, Secretary of State for the Environment George Eustice has signalled his intent, announcing ambitious-sounding plans to restore biodiversity, making it illegal to fail. EXCEPT ....

…in this updated version of a blog first posted on 22 May, I bring you the depressing news of his failure – 22 days on. This is the hopeful blog I originally wrote, annotated with the reality:

Golden eagles and wildcats are among the animals which could once again live in England, under new plans announced by the government on Tuesday. This was always on the cards, since of all the announcements George Eustice could have made, reintroducing some of England’s most charismatic former denizens was guaranteed to grab the headlines.

Less certain was whether he would respond to two demands that the conservation sector has long seen as critical: setting legally binding targets for biodiversity’s restoration, and banning sales of peat-based products for horticulture. Eustice’s speech, given from a restored peat bog in Delamere Forest, Cheshire, didn’t disappoint, and conservationists have given him a cautious thumbs-up.

But tucked away was another announcement, a technical detail that won’t have excited many journalists, and even fewer editors. Conservation professionals certainly took note, though: there is to be a review of the Habitats Regulations.

Secretary of State George Eustice

Let’s look at each of those issues in detail, but first, some context.

In 2002 the world’s governments met as signatories to the Convention on Biological Diversity, which had come into force nine years earlier. At that meeting they agreed to achieve by 2010 a significant reduction of the current rate of biodiversity loss at the global, regional and national level as a contribution to poverty alleviation and to the benefit of all life on earth.

As 2010 drew closer they had to acknowledge that their aim was probably never likely to have been realised, so the 2010 Conference of the Parties to the convention, or CoP, drew up a new strategy for 2011-2020. More sophisticated, more detailed, and more focussed on specific goals, it did away with the one-line proclamation of some grandiose aim. Instead, the Parties adopted twenty targets, the so-called Aichi Targets, after the Japanese prefecture in which they were drawn up. They all begin with the words “By 2020 …” and include:

…incentives, including subsidies, harmful to biodiversity are eliminated, phased out or reformed in order to minimize or avoid negative impacts (target 3)

…the rate of loss of all natural habitats, including forests, is at least halved and where feasible brought close to zero (target 5)

…all fish and invertebrate stocks and aquatic plants are managed and harvested sustainably, legally and applying ecosystem-based approaches, so that overfishing is avoided (target 6)

…areas under agriculture, aquaculture and forestry are managed sustainably, ensuring conservation of biodiversity (target 7)

…the extinction of known threatened species has been prevented and their conservation status, particularly of those most in decline, has been improved and sustained (target 12)

Conservationists fear that a pattern has emerged and will be repeated decade after lost decade. The 2002 failure was followed in 2010 by a resetting of the clock, adding another ten years to the timescale – to 2020. The governments failed again, against every substantive target. These failures were not close calls, just falling short, but comprehensive, outright, abject debacles. A Biodiversity CoP was due to take place in Kunming, China in October 2020, but has been postponed until October this year in the wake of the Covid-19 crisis.  The next month, the UK hosts another CoP – that of the UN Climate Convention – in Glasgow.  Activists, including the RSPB, advocate nature-based solutions to climate chaos in a bid to solve these twin crises. The connection between the two is increasingly well understood.

Cotton grass moor, a peat-rich upland habitat in the South Pennines

Peatlands for climate and wildlife

While much of the world’s attention is on protecting and expanding forests to sequester carbon, one of the biggest contributions the UK can make is in protecting peatlands, at home and abroad. In his speech, George Eustice set out new proposals to protect and restore England’s peatlands to help achieve the government’s goal of bringing net greenhouse gas emissions to zero by 2050. The proposals include funding to restore 35,000 hectares (86,000 acres) of degraded English peatlands in the next four years. This is about 1% of the UK’s total, and it is important to remember that while the UK’s peatlands are globally important, much of it is in Scotland and Northern Ireland, where Mr. Eustice’s writ does not run. Ahead of the two CoPs, he needs to persuade his counterparts in the rest of the UK to fall into line. The government also plans to ban sales of peat compost for amateur gardeners, which is sourced both in the UK and in other peat-rich countries like Estonia, by 2024.

Healthy peatlands store three times as much carbon as the same area of forest.  But only a fifth of the UK’s 2.6 million hectares of peat is in good enough condition. Overall, from the fens of East Anglia to the Flow Country of northern Scotland, peatland may release as much as 23 million tonnes of carbon more than it sequesters, according to a report published this month by the British Ecological Society.

The report runs to 190 pages of evidence from more than 100 ecologists to show the importance of good ecosystem management for slowing and limiting runaway climate chaos. To put it another way, it offers a green bridge between Kunming, China, and Glasgow, between decisions made on biodiversity in October and those made on climate a month later.

Wildlife and Countryside Link, the policy wing of the conservation NGO sector, had earlier published its views on what is essential content for the government’s England Peat Action Plan. Now the long-awaited plan is finally here, how does it compare? “Fairly well” say WCL, whose member organisations have campaigned for decades for some of the measures announced in the plan. WCL say they are “heartened that the Government favours a ban on amateur sales, and it must see this through to a total ban throughout the horticulture sector.”

The Wildlife Trusts’ chief executive Craig Bennett said the government’s initial target to restore 35,000 hectares of peatland was disappointing and called for a commitment to restore all upland peatland and at least a quarter of lowland peat. WCL is also disappointed that the Plan stops short of committing to binding targets for the protection and restoration of our peatlands, and previously-announced controls on burning as a management practice on peatlands (primarily for grouse shooting) contain serious loopholes. Until proper targets and funding are in place and the burning issues are resolved, the job isn’t over.

Legal commitment?

A peatland target may be lacking, but for nature as a whole “we will be amending the Environment Bill to require an additional legally binding target for species abundance for 2030, aiming to halt the decline of nature,” said Eustice. Wildlife and Countryside Link and its constituent bodies, such as the RSPB and the Wildlife Trusts, can chalk that one up as a success for their powerful State of Nature campaign which has garnered over 165,000 signatures so far.

The reality…

Update 9 June: for the latest, read Wildlife and Countryside Link’s analysis here, but in summary, they report:

  • On 18 May the Environment Secretary promised a “Net Zero equivalent for nature” through a “legally binding target for species abundance for 2030, aiming to halt the decline of nature”.
  • This followed a campaign for a “State of Nature” target to halt nature’s decline by 2030, supported by 70 organisations and over 180,000 people.
  • In an about face, the Government has published an amendment that does not set a target to halt nature’s decline.
  • Environment charities warn this is not a Net Zero for nature and have written to the Prime Minister to say that this undermines his promise of international leadership ahead of the (UK-hosted) G7 and COP 26 and at COP15 climate and nature talks.

DEFRA and Natural England are now working on a ‘Nature Forward Look’ in advance of the Kunming Biodiversity Convention meeting, including proposals for how the government will take this new species target forward. Over the next few months they will work on defining the target itself, and the strategy to deliver it, including costs. An encouraging sign is that Eustice’s speech acknowledged that “the UK is sadly one of the most nature depleted countries in the world. Over the last 50 years, much of the UK’s wildlife-rich habitat has been lost or degraded, and many of our once common species are in long-term decline.”

We want not only to stem the tide of this loss, but to turn it around and leave the environment in a better state than we found it. I want us to put a renewed emphasis on nature’s recovery.

George Eustice, 18 May 2021

It will be crucial that NGOs, and the Government’s own advisers, Natural England, push for a target that actually reflects that goal. It is not clear how the plethora of data that is needed to assess the state of nature can be distilled down into a single indicator, but it must be done. More than two decades on, nature is still suffering the consequences of previous governments’ disastrous target-setting for the condition of Sites of Special Scientific Interest.[i] A similar sham approach for species would destroy any credibility the Secretary of State may have gained from this week’s announcements.

The species target is a late addition to go alongside a suite of others that will be outlined in the Environment Bill, currently making its way through Parliament. The details will come through secondary legislation, involving a less transparent process under much more Ministerial control. The secondary legislation in question is the Habitats Regulations, and George Eustice wasted no time tabling a government amendment to the Bill, giving himself and his successors as Secretary of State power to amend the HabsRegs, as they are universally known outside legal circles. He has long despised them: during his campaigning for Brexit, Eustice described the HabsRegs as ‘spirit-crushing’. This contrasts with conservation professionals’ view that they have been key to safeguarding the most important sites and habitats from damage in the face of development proposals. So conservationists will need to follow closely any proposals to ensure that they strengthen, rather than further weaken, that protection.

[i] The official target for protected areas set by the governments of England, Scotland, Wales and Northern Ireland was for 95% of Sites of Special Scientific Interest to be in favourable or ‘unfavourable recovering’ condition by 2020 – comprising 50% favourable, 45% unfavourable ‘recovering’.  The original date set for achieving this goal, 2010, was missed by a mile.  The term ‘recovering’ is misleading:  it means that “under current management conditions the site is likely to become favourable over the course of time.”  The time period is not specified, and management is invariably based on short-term agreements under schemes whose future is uncertain.  To obfuscate further, the government’s spun-out version of the term is ‘target condition’ – a combination of favourable and unfavourable (but supposedly recovering); and this has been further spun into “the very best condition” in at least one Natural England report.  An example of the impact of this obfuscation can be seen in the Dark Peak SSSI assessment for 2016 (there hasn’t been one since): the SSSI is shown as 97.73% meeting the target condition, but that figure comprises 4.33% favourable, 93.41% – amounting to 71,340 acres – unfavourable, and allegedly recovering.  Assessments clearly show on-going bad management practices even on the so-called ‘recovering’ areas.  

Headline indicators or indicator headlines?

Some of the most hopeful conservation stories of recent times concern reintroductions of species lost to Britain. Current programmes for white-tailed eagles and beavers are hugely popular and regularly make for positive headlines. So it is no surprise that Secretary Eustice headlined his own announcements with crowd-pleasers like golden eagles and wildcats. It is worth pausing on wildcat for a moment. Technically, it is already ‘functionally extinct’ due to its remaining populations, all in Scotland, being regarded as no longer viable. It is better than being actually extinct, because there remains a small hope of recovery. The only hope, though, is in Scotland, with none at all in England. Hybridisation with domestic cats is a major threat, and it is unlikely that many pure-bred wildcats exist at all. Vast expanses of wild habitat are needed to allow the wildcat to roam and to recover. There is simply nowhere in England like that. If we can’t save the wildcat in Scotland, we won’t save it in England.

Wildcat: the opening page of Framing Nature by Laurence Rose
(illustration by Richard Allen)

That bizarre example aside, Eustice’s list of species to be considered for reintroduction or translocation include the red-backed shrike, the curlew and the golden eagle. If there is a wider strategy behind this, then they are an exciting choice, signalling an appetite for radical change. All three species will require wholesale transformation over large tracts of countryside to succeed. It will be no good just letting a few shrikes flutter from their cages in islands of nice habitat like Knepp, or rearing curlew chicks in captivity for ever more, to save them from early mowing and predators.

I am not aware of any such strategy, but I do know that one is on the drawing board within DEFRA, who have in the meantime just released guidance to anyone contemplating reintroducing anything. If the point behind the focus on charismatic species is to boost nature as a whole, then for ‘reintroduce red-backed shrike’ read ‘restore large insect populations following their catastrophic crash’; for ‘release curlew into areas from which they have been lost’ read ‘transform large areas of lowland grassland’; for ‘reintroduce the golden eagle into England’ read ‘rewild large tracts of the uplands and crack down on wildlife crime’.

Red-backed shrike photo: Laurence Rose

These would be feasible goals, if this is the ambition. One of the government’s earlier headline ambitions, in the 25 Year Environment Plan published in 2018 and not yet under way, is the Nature Recovery Network (NRN). This aims to create or restore 500,000 ha. of wildlife-rich habitat outside protected areas, while restoring 75% of SSSIs to favourable status – by 2042. Alongside the Prime Minister’s announcement in September that 30% of England will be protected for nature by 2030 (with encouragement to the rest of the UK to join in), this is beginning to sound like a scale of ambition at which a new deal for lost and declining species may just work.

But are those pledges designed to direct conservation effort, or to deflect headline-writers’ attention? The ‘thirty percent’ pledge claimed that we were nearly there, with 26% of England already covered by the network of SSSIs, National Parks and Areas of Outstanding Natural Beauty. Another four percentage points, roughly the area covered by the proposed NRN, would get us there.

Except, of course, that most of that 26% isn’t designated for wildlife, none of it has full, robust protection, and only about 3% of land is managed well for conservation. If the Nature Recovery Network proves to be outstandingly successful, that brings us to 7%. So the challenge is huge – which is good. It means that rising to the challenge successfully will transform England (and hopefully the UK) and will transform life for its inhabitants, human and non-human alike – if that is actually what the government means by its headline announcements. It seems a big if, for now.


It took three weeks for the Secretary of State’s headline-grabbing ‘commitment’ to be exposed as yet another failure of leadership. Beccy Speight, CEO of the RSPB, said“No ifs or buts. Nature in the UK is in deep trouble and that’s an ongoing and growing disaster for both people and wildlife. We have a once in a generation opportunity to start to fix this through a strong Environment Bill for England. Prevaricating and weak wording in the proposed amendment will fail all of us. We need a strong, clear amendment that will provide the legal backbone to halt the decline of nature by 2030 and we need to strengthen the protection of species and the most important places for wildlife to make that possible on the ground. Either we want to do this or we don’t, in one of the most nature depleted countries in the world – and the Prime Minister has said many times on a global stage that we do want to do it. So let’s do it.”

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