Written by Henrietta Appleton, Policy Officer (England)
This week the Government published an updated Environmental Improvement Plan (EIP) following the rapid review initiated in July 2024. This revision now links the goals with commitments and actions so there is a pathway to delivery. But will these actions achieve their aim?
The EIP re-asserts the statement “We know England has become substantially nature depleted”. As we have contended in a previous blog (Are we one of the most “nature-depleted” countries? - Game and Wildlife Conservation Trust) the Biodiversity Intactness Index (BII) behind the term “nature depleted” is inappropriate for a heavily populated, industrialised and ‘managed’ country like the UK as its basis is a comparison with un-disturbed landscapes. Such approaches support the trend towards making our environment ‘wilder’; but is this a misnomer? Should re-wilding actually be re-naturing? Whilst we do not contend that nature has declined in the UK, understanding the causes of those declines and how species or assemblages have adapted to human disturbances over time (centuries in fact) is important to getting the countering actions right. Indeed, human disturbance also involves the introduction of species which now, and in some cases for many centuries, live and breed here successfully. Some of them, such as the brown hare, are much valued, but not included in the BII; and there are many more “naturalised” species in this category. Basing our view of nature’s recovery on its decline from an undisturbed ‘wild’ site (the return to which is nigh on impossible) or on ideologies which restrict necessary conservation actions is unhelpful.
So what of the EIP commitments and actions that underpin the “over-arching goal” of restoring nature (goal 1)?
There are encouraging words on partnerships, regulatory reform and on mobilising businesses and private finance as enablers of the ambitions in the EIP, such as the plans for streamlining and strengthening nature market governance late in 2026 and sustainability reporting. But the evolution of the co-existence of the new Nature Restoration Fund alongside the statutory and voluntary markets for development impacts will be observed closely as to whether it constricts private sector involvement. In addition, the long-awaited Land Use Framework we hope will be just that – a guiding document to enable decisions to be made on trade-offs by land managers, not policy makers. Equally the farming roadmap we hope will provide the certainty needed for this industry and start to rebuild the loss of confidence. After all land managers and farmers underpin the majority of the actions and commitments in the EIP.
Progress on 30by30 (commitment 7) has arguably stalled with a 30by30 action plan “in due course”. Yet time ticks on. There are now only 4/5 breeding seasons (although not all species breed in their first year) until 2030, the deadline for the statutory target to halt the decline in species abundance (commitment 15). The 30by30 commitment would be a significant foundation to this success yet there is no clear path as to how other effective area-based conservation measures (OECMs) are to be supported. This is a missed opportunity and one that needs addressing quickly (as part of restoring rural land managers confidence?) as it could embed the principle of blended finance and reduce reliance on public money for environmental delivery. GWCT CEO Nick von Westenholz in his recent piece in Country Life commented on this and how tax incentives could be used to incentivise land managers to commit land that meets environmental standards to 30by30. Yet the action to foster multi-landscape, large scale nature recovery initiatives is being led by the Protected Landscapes Partnership reflecting, I presume, a commitment (commitment 9) to increase the contribution these landscapes make to targets. I think it is often forgotten that these bodies are created by putting lines on a map and they rely on the land managers and farmers that lie within their boundary for delivery. Spending money on these administrative areas gets diluted before it gets to the actual land manager. Surely it is more cost effective (Treasury are you listening?) to direct that money to the land manager in the first place and for the Protected Landscape bodies to provide the guidance and on-going monitoring of outcomes that would ensure adaptive approaches at each site/farm/estate?
We welcome the commitment to targeted action to conserve and recover threatened species (commitment 14), and the underlying actions based on the Species Recovery Programme and agri-environment measures. But we say again (and again, and again) that simply addressing habitat will not work for all species, as we have proven more than once on our demonstration farm, the Allerton Project (members will be tired of us saying this!). Adding salt to this wound is an action under commitment 15 to halt the decline in species abundance by 2030 to follow through on the manifesto commitment to end the use of snare traps. These have been proven to support the conservation (and recovery) of ground-nesting species such as curlew and black grouse. We estimated that 37% of species on the red list (as at January 2025) benefitted from legal lethal predation management. Back to my point about ideologies restricting conservation actions.
In fact, encouraging rather than restricting game management practices would also underpin the delivery of other actions such as woodland planting (commitment 11), woodland management, manage the impact of mammals on woodlands better (both actions under commitments 7-9), hedgerow planting and restoration (commitment 12) and increased private investment in woodland (an action under commitment 1). It would also facilitate actions to restore 280,000ha of peatland (commitment 64) as it is often overlooked that many grouse estates commenced grip blocking well before it became a trendy conservation measure. The wet flushes and microtopography that are a feature of a healthy peatland support the life cycle of the red grouse and other threatened upland species (A bastion for birdlife: The Raby Estate in County Durham - Game and Wildlife Conservation Trust).
We also question whether ambitions for farm wildlife have been weakened. The EIP2025 states under commitment 16 that “by December 2030, double the number of farms providing sufficient year-round resources for farm wildlife, compared with 2025” whereas the EIP2023 states that 65-80% of landowners and farmers will adopt nature friendly farming on at least 10-15% of their land by 2030. Although now an interim target, “sufficient year-round resources” as opposed to a % area committed is arguably more difficult to monitor.
One of the building blocks of species recovery (commitment 15) is reintroductions of native species. Whilst we support this, as is evidenced by our work on grey partridges and black grouse, we are at pains to point out that many reintroductions do not comply with IUCN/Defra guidelines. Compliance is not mandatory which is a shame as money is being wasted reintroducing captive bred individuals or through headstarting without a comprehensive assessment of why they declined in the first place, whether all their needs are being met and how any conflicts might be addressed or mitigated. We would like to see the England Species Reintroduction Taskforce take a lead on this as part of their action to provide guidance. We are falling into the dangerous trap of being distracted by the introductions of “new” and iconic species which attract media coverage whilst all else around continues to decline.
The EIP is obviously more comprehensive than just the commitments and actions under Goal 1 “Restore nature”. It addresses ambitions to improve environmental quality, support sustainable soil management (although we note that the focus is on soil health and not the 50% of global biodiversity held in soils), reduce waste, adapt to climate change, reduce environmental hazards and encourage access to nature and many of these are inter-connected with goal 1 as is made clear in the EIP. This blog would be rather lengthy if it addressed them all, but it would be wrong not to suggest that there are developments which are to be welcomed such as the commitment to chalk stream habitats (commitment 28) and an action to mandate biodiversity net gain (BNG) for nationally significant projects and support off-site BNG.
But as with all policy statements, strategies and frameworks it is whether the desired outcomes are achieved and, in this respect, we hope the actions speak louder than the words, because we are running out of time.