LGA response to Defra consultation on environmental targets

It is helpful to see Defra’s thinking on the scope of long-term environmental targets. As a next step, Defra needs to set out clear implementation plans with interim targets.


Key messages

The LGA's response to Defra's consultation on environmental targets

  • It is helpful to see Defra’s thinking on the scope of long-term environmental targets. As a next step, Defra needs to set out clear implementation plans with interim targets. Long term environmental targets must be matched with sustainable sources of funding and embedded across government. If any of the proposed national targets are applied to local government, this must be accompanied by funding for new burdens.
  • For some target areas such as water, air quality and biodiversity we want to see Defra raise the level of ambition.
  • Many of the environmental issues flagged in the consultation paper are already acute and present wider challenges to the health and economy of local communities. For example, the moratoriums on housing development in the river catchment areas affected by high levels of nutrient pollution. 

Biodiversity targets

The proposed targets:

  • increase species abundance by at least 10 per cent by 2042, compared to 2030 levels.
  • improve the England-level GB Red List Index for species extinction risk by 2042, compared to 2022 levels.
  • 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

Questions:

Do you agree or disagree that the proposed combination of biodiversity targets will be a good measure of changes in the health of our ‘biodiversity’?

Agree, subject to the comments below.

It is essential for any target to have robust historic data and data recording schemes to analyse trends and identify anomalies over time. Habitat restoration and protection are essential in facilitating species abundance but when analysing data, consideration needs to be given to the effects changes in our climate are affecting the presence of particular species in particular locations. 

In order for targets to be meaningful, they need to be linked to an implementation plan with deliverable milestones and owners.

Do you agree or disagree with the ambition proposed for the long-term species extinction risk target to improve the England-level GB Red List Index?

Agree

The proposition of a species extinction risk target which will focus on the recovery of threatened and near threatened species, to complement the species abundance targets, is a practical approach to improving the England level GB Red List Index of species extinction risk. The LGA considers this is positive action that will reflect recent trends in biodiversity decline that could lead to the development of action orientated implementation plan.

Ahead of the development of an implementation plan, a detailed understanding of species decline, and extinction risk needs to be reached. Using a subset of species assessed at the Great Britain level to create a new Red List Index that is more representative of species in England is a practical and important start for ensuring actions that follow are targeted, deliverable and measurable.

Do you agree or disagree with the level of ambition of ‘in excess of 500,000 hectares’ proposed for the long-term wider habitats target?

It would be helpful to understand how the target will support “net gain” of new habitat, as far as possible.

In general, the LGA supports the level of ambition of ‘in excess of 500,000 hectares’ proposed for the long-term wider habitats target and that all wildlife-rich habitat types should count towards the target but believes Government should be more specific with regards to what ‘in excess’ means. It is also important that all habitat types count towards this target and that no habitat types are excluded.

Measuring this target will be essential in determining progress and where this requires data reporting from councils, the cost of gathering, compiling and reporting data through  Biodiversity Net Gain or Local Nature Recovery Strategies should be considered a new burden and fully funded.  Environmental reforms, such as Local Nature Recovery Strategies, must be embedded into planning reforms. We welcome further detail from Defra and DLUHC on how this will be achieved.  

Target proposals to improve water quality and availability

The proposed targets:

  • Nutrient targets: to address the two principal sources of nutrient pollution by 2037:
    • Reduce nitrogen, phosphorus and sediment pollution from agriculture to the water environment by at least 40 per cent by 2037 against a 2018 baseline.
    • Reduce phosphorus loadings from treated wastewater by 80 per cent by 2037 against a 2020 baseline.
  • Water demand: Reduce the use of public water supply in England per head of population by 20 per cent by 2037 against a 2019/20 baseline

Questions

In addition to the proposed national target, we would like to set out ambitions for reducing nutrient pollution from agriculture in individual catchments. Do you agree or disagree that this approach would strengthen the national target?

Disagree

We believe the national target itself should be more ambitious and that agriculture in all river catchments should have suitably strong targets – and so only having additional targets  for some catchments would not sufficiency strengthen the national target.

We recognise that some catchments suffer from greater levels of nitrates and phosphates from agriculture than others – such as those impacted by the nutrient neutrality determinations - and do support heightened ambitions for these catchments in both quantity and pace. However these should be in addition to a more ambitious reduction at the national level.

The target needs to allow flexibility for water companies to use best available strategies to reduce phosphorus pollution, including the use of nature-based and catchment-based solutions. Do you agree or disagree that the proposed target provides this flexibility?

Agree

We recognise the value of flexibility and that different solutions will be valuable for different areas. However, the means for reducing phosphates pollution must be sustainable in the long-term, and interrelated with the wider local strategic ambitions and approaches to land-use – for instance related to Local Plans, Local Nature Recovery Strategies, Bio-Diversity Net Gain, and so on.

Do you agree or disagree with the level of ambition proposed for the nutrient targets?

Disagree

The Government needs to be more ambitious in both the scale of reductions and the time frames and the policies to achieve them, in particular for agriculture. This is necessary for the environmental protection and recovery of all rivers, and it is particularly acute for river catchments subject to house building moratoriums due to excess nutrient pollution. 

Our analysis suggests something like 17,000 homes every year are impacted by nutrient neutrality moratoriums on development. Nature-based solutions are unlikely to unblock this, and it is important to reduce nutrient pollution at source both for the health of the rivers and their ecosystems, as well as sustainable development and growth.

Further, the individual policies and investments set out to contribute towards the achievement of targets should be explicit in the level of nitrate and phosphate reductions they would each achieve in isolation and the total contribution of measures to achieving the target.

Do you agree or disagree with the level of ambition proposed for a water demand target?

Disagree

The target timeframes could be more ambitious. Further, this target could be divided into contributory targets, for instance creating or reviewing targets on reducing water lost via leaks and poor infrastructure, water efficiency of new and existing buildings, and usage in households and non-households.

Many local authorities are now in water-stressed areas and that this is a national issue which requires acceleration of investment in both public and private for upfront infrastructure (grey and green infrastructure) for integrated water management to provide enough water for the levels of house-building and existing demand needed. It is right to take steps to reduce water demand this alone is not enough.

Target proposals for woodland cover

The proposed target:

  • Increase tree canopy and woodland cover from 14.5% to 17.5% of total land area in England by 2050.

Questions

Do you agree or disagree with the proposed metric for a tree and woodland cover target?

The proposed metric is measurable and meaningful to a non-technical audience. Councils are keen to work in partnership with communities and local landowners to increase tree cover by planting new trees. At the same time, many of our native tree species are threatened by pests and diseases and have been taken down for safety and to slow the spread of infection. It may be helpful for Defra to review progress against the target alongside other measures that give an indication of the health of our trees. While this is presented as an environmental target, councils are keen to see trees planted in communities lacking in access to nature, and in areas where they can help increase resilience to climate change.

Do you agree or disagree with the proposed inclusion of trees in woodlands, as well as trees in hedgerows, orchards, in fields, and in towns and cities?

Agree, on the assumption that the data underpinning the target would be detailed enough to highlight any gaps in tree cover.

Target proposals for resource efficiency and waste reduction

The proposed targets:

  • Reduce residual waste (excluding major mineral wastes) kg per capita by 50 per cent by 2042 from 2019 levels. It is proposed that this will be measured as a reduction from the 2019 level, which is estimated to be approximately 560 kg per capita
  • We are exploring how we might measure this as a ratio of economic output (gross domestic product) in money value to raw material consumption (excluding fossil energy carriers) estimated by material weight (i.e. gross domestic product divided by raw material consumption).

Do you agree or disagree with the proposed scope of the residual waste target being ‘all residual waste excluding major mineral wastes’?

Disagree

The exclusion of major mineral wastes significantly reduces the ambition of the target. Mineral waste, consisting of waste from construction and demolition such as bricks and concrete plus mineral waste from mining and other activities, was the largest category of waste in the UK at 84 million tonnes. Household waste made up 12 per cent of all waste generated, by contrast. Defra acknowledge that the lack of data is one of the reasons for excluding major mineral waste, and this data gap needs to be addressed.

Do you agree or disagree that our proposed method of measuring the target metric is appropriate?

Agree

Measuring the volume of waste sent through various disposal routes can be easily understood and this is already collected as part of household waste and recycling statistics. Dividing this figure by the amount of people in the population allows for progress to be tracked over time. Defra may wish to consider whether this is best done per person or by household, noting that many councils base their analysis of waste data on households.

Do you agree or disagree that local authorities should have a legal requirement to report this waste data, similar to the previous legal requirement they had until 2020?

Disagree. The local authority sector provides waste data as part of national statistics. It is already recognised that data collection systems need to be reformed  to support the implementation of Extended Producer Responsibility for packaging and through reforms to waste tracking systems. Defra must consider the opportunity to streamline data collection systems and reduce the burden on councils.

The big gaps in data are to be found in other sectors, notably business waste and construction and demolition waste. The focus should be on bringing all sectors up to the same standard of data collection.

Do you agree or disagree with the level of ambition proposed for a waste reduction target?

Agree.

It is right that Defra has set a high level of ambition the target for reducing residual waste. The strategy for achieving the target needs work, however. Defra must have a clear focus on waste prevention, as reducing waste in the first place has the best environmental outcome. The consultation sets out how Government will work with local government to increase recycling, but there are gaps in the strategy for reducing waste, for example in dealing with municipal offensive waste items that frequently end up in the household residual waste bin e.g., nappies, hygiene products, and incontinence pads. As household waste is only 12 per cent of the total waste generated, Defra needs a clear strategy for ensuring that other sectors are making an equally strong contribution to the waste reduction target.

Do you agree or disagree with our proposed metric for considering resource productivity?

Expressing resource productivity in a simple metric is very difficult. Defra’s thinking is at an early stage and there is not enough information for the LGA to be able to comment. In view of this Defra may wish to propose some interim targets that can be easily measured.

Of the possible policy interventions described, which do you think will be most effective to meet a resource productivity target? Please specify whether these policies would be most effective if implemented nationally or regionally, and whether measures should be product or sector-specific.

The LGA supports all the measures proposed: extended producer responsibility schemes, eco-design measures on producers and better information on consumers. All of these are levers that will support a more circular economy.

Defra should consider what more could be done to reduce the pressure on scarce natural resources, for example by helping people move away from a linear model of consumption and disposal to models based on leasing and renting. We welcome further information on next steps.

Target proposals for air quality

The proposed targets:

  • Annual Mean Concentration Target (‘concentration target’) – a target of 10 micrograms per cubic metre (µg m-3) to be met across England by 2040.
  • Population Exposure Reduction Target (‘exposure reduction target’) – a 35 per cent reduction in population exposure by 2040 (compared to a base year of 2018).

Questions

Do you agree or disagree with the level of ambition proposed for a PM2.5 concentration target?

Disagree

The government needs to be more ambitious in the timescale of improvements. Government must provide the support to help local authorities provide healthier air for communities faster than proposed. The government should aim to hit the WHO’s 2005 aim for its AMCT of PM2.5 of 10 micrograms per cubic metre by 2030 instead. This shorter timescale is required to incentivise central government to furnish local authorities with the powers, resources and wider support to take immediate action to reduce domestic combustion, monitor and enforce compliance in industry and reduce road transport as a source of PM2.5.

Whatever target is settled upon, local authorities will need the long-term funding and support to make use of the enforcement powers set out in the Environment Act and the DfT’s ambitions for Local Transport Plans.

Do you agree or disagree with the level of ambition proposed for a population exposure reduction target?

Disagree

A more ambitious concentration target should be the backstop for a more ambitious exposure reduction target that is more directly focused on improving public health. The government should aim to make these improvements by 2030 alongside background concentrations. Local authorities with the most acute public health problems caused by poor air quality must receive greater resources to take appropriate measures to improve public health equitably. The government should aim to hit the WHO’s 2005 aim for its AMCT of PM2.5 of 10 micrograms per cubic metre by 2030 instead. This level of ambition is required for central government to furnish local authorities with the powers, resources and wider support to take immediate action to reduce domestic combustion and road transport as sources of PM2.5.

Whatever target is settled upon, local authorities will need the long-term funding and support to make use of the enforcement powers set out in the Environment Act and the DfT’s ambitions for Local Transport Plans.