DEFRA releases ‘flimsy’ wildlife and water evidence

Under pressure from green groups, DEFRA has finally published the outstanding evidence it used to create its proposed new environmental targets, but a dearth of baseline data and a reliance on action-based goals have failed to impress wildlife and water experts.

The Environment Act 2021 requires the government to set at least one long-term biodiversity target alongside targets for water, air quality and waste management. On 16 March, DEFRA published its proposed targets for consultation, which were met with dismay by environmental organisations, but the department failed to publish the evidence on which the targets were based. 

Following an outcry from environmental NGOs, DEFRA eventually published the evidence at the end of last week and extended the consultation’s deadline to 27 June.

But the evidence packs have done little to allay concerns. The RSPB’s Philippa Goodwin described the evidence as “gappy”, “flimsy” and that it revealed a “paucity of data on so many species”. 

The problem stems from the Environment Agency and Natural England's historic and ongoing lack of robust monitoring, say green groups, which has led to a dearth of data on which to create firm baselines, and makes it difficult to set quantifiable targets. 

As a result, many of the targets are based on actions and their modelled results, rather than outcomes themselves. “There are a lot of actions but I can’t see very much ground-truthing,” said Goodwin. 

DEFRA has set a target to create or restore in excess of 500,000 hectares of a range of wildlife-rich habitats outside protected sites by 2042, compared to 2022 levels, but DEFRA “is not subtracting habitat lost and is not including those where quality has declined”, said Goodwin. Without data and hard ground-truthing the eventual picture could be one of overall decline, she added. 

READ MORE: Gaps in DEFRA’s nature metric revealed as evidence backing up environmental targets emerges

Similarly, DEFRA has set a target to improve the England-level GB Red List Index for species extinction risk by 2042, compared to 2022 levels, but “improvement is not a measurable target”, said Goodwin. The resourcing needed to assess the existing extinction risk and to create an index would require a large investment from government but “there is no costing in DEFRA’s impact assessment”, she noted. 

Buglife’s Matt Shardlow said it was a “disgrace that so many threatened pollinators are not being included in DEFRA’s monitoring statistics” in light of the rapid decline in their numbers. “Currently in England flying insects are declining at an average rate of 3.8% per year, so the continued decline plus the 10% uplift from 2030 levels would mean that there would be 24% fewer insects in 2041 than there are now,” he said. 

Wildlife and Countryside Link’s Dr Richard Benwell echoed the concerns: “The biodiversity targets could mean that wildlife is less abundant in 2042 than it is today, that protected sites remain in poor condition, and that there is an overall loss of priority habitat across the landscape. 

“The government should strengthen the targets to reflect the promise of passing on nature in better condition, to ensure that our most precious wildlife sites are properly cared for, and to ensure that promises of habitat creation take losses into account as well as gains.”

The freshwater goals suffer from the same problem, according to rivers groups. “These environment targets should quantify whether the environment will be in a better state for the next generation, which is the government’s stated aim,” said Mark Lloyd of the Rivers Trust. “They fail to do that because they focus solely on an individual pollutant – phosphate – from two sectors, rather on the overall environment outcome, which is river health.  This approach will fail to address other pollutants, such as nitrogen and chemicals, and other sectors such as urban and industrial effluent.”

Lloyd also expressed concern about what he describes as the inadequacy of existing monitoring regimes to provide reliable baselines. “How can we know whether pollution from a sector has been reduced by 80% if we don’t know with any accuracy the contribution of that sector today?  Overall, this appears to be a hasty and spurious approach to target setting, that will fail to provide the drivers for the urgent ecological restoration we so desperately need."

Benwell said the water targets miss out important sources of pollution, such as nitrogen in wastewater and rely too heavily on modelled results, rather than in-river readings. “Most importantly, perhaps, there is no long-term target for the actual condition of the freshwater environment to drive improvements and accountability after the Water Framework Directive targets expire in 2027. That risks reducing political certainty needed to drive private sector investment. It also risks undermining public transparency and trust,” he said.

Salmon and Trout Conservation’s Dr Janina Grey said she is ”incredibly disappointed” at the “lack [of] an outcome based target for freshwater ecology - which is fundamental to ensure real on-the-ground biodiversity improvements”. She said the nitrogen and phosphorus targets are ‘business as usual’ repacked, and “with agriculture arguably the biggest threat to freshwater ecology, we need additional measures to make real improvements... these proposed targets indicate it will fail our freshwater habitats and wild fish populations and allow polluters to continue to take advantage”.

Fish Legal’s Penny Gane said setting targets for freshwater species “is going to be hampered by a lack of sufficiently detailed and consistent Environment Agency data” and that there have been very few repeat surveys for the 30 freshwater fish species found in English rivers being considered”. 

Gane said the Environment Agency was using crude measures “such as family-level recording to monitor freshwater invertebrates up until 2017 with regional variations of how the Environment Agency approached their monitoring,” and added that the agency has said it has not conducted enough surveys or collected enough data on a wide range of plant and animal species. 

“In short, they do not appear to be ready to set meaningful targets for freshwater biodiversity,” she concluded. 


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