We respond to Defra consultation on environmental targets

NFU Deputy President Tom Bradshaw said: “British farmers are passionate about maintaining and enhancing our countryside; providing a variety of habitats to support wildlife and plant species, protecting watercourses and reducing emissions.

“It is important that the future framework for new environmental targets delivers for the needs of agriculture and the environment, and it’s absolutely critical the government’s ambitions sit alongside equally ambitious plans for domestic food production and UK food security.      

“To deliver these ambitious targets, Defra needs to recognise the important role farmers and growers play. Ongoing engagement with farming is crucial, as is linking with the new Environmental Land Management schemes where appropriate.

“Moving forward, these targets need to be achievable and affordable for the farmer sector, and crucially based on science and evidence.”

Defra's consultation on environmental targets closed on 27 June 2022.

We submitted a full response. You can read it in full here: NFU response to Defra consultation on environmental targets June 2022 (PDF download, 432 KB)

In our response we highlighted the willingness of farmers to continue to play a huge role in meeting the environmental challenges of our countryside, alongside providing food for the nation.

We also set out our concerns about the:

• achievability of the proposed targets
• extent of possible land use change that may be needed as a result of meeting the targets
• heavy reliance on the new ELMs (Environmental Land Management scheme) to deliver the targets
• unaccounted cost to agriculture of achieving the targets
• short timescales that Defra is working towards to have statutory instruments in place, leaving little time for full consideration of the consultation responses. 

NFU view

Our view is that any new targets must:

• have a clear evidence base for inclusion
• have a clear baseline
• be achievable, measurable and affordable
• have the right supportive policy mechanisms in place.

Concerns raised

We are concerned about the highly ambitious programme of land use change and management to achieve a number of the targets. This includes woodland cover target (3% land use change) and the long-term species abundance target (by implication a 5% land use change) but particularly the water quality in agriculture target (20% land use change) and the subsequent significant impact on food production, in terms of food security but also land values.

It is concerning to us that these proposals appear to conflict with food production. They would require a long-term or irreversible change to the productive capacity of farmland, such as tree planting and re-wilding. 

ELMs

We note the extent to which Defra places significant emphasis and expectation of participation in ELMs and uptake of different options or measures in ELMs to deliver on the environmental targets. With the SFI (Sustainable Farming Incentive) scheme still at development stage along with the wider ELM offer, all due to be more available in 2024, it is impossible to say if uptake of ELMs will meet the level of ambition to deliver.

Affordability

It is also of concern to us that the impact assessment does not consider the impact of individual policies, in terms of who would bear the costs and what impact this would have on individual businesses, land use change and food security. These are huge gaps in the analysis. Affordability to the agriculture sector must be a key test, yet it appears to have been ignored.

Timescales

We are concerned about the tight timescales that Defra is operating within after the close of the consultation. This current timetable does not allow enough time for Defra to give careful consideration to the consultation responses and adequate time to rethink whether these targets are achievable and affordable.

Our expert advisers wrote a briefing for members guiding them through the detail of the consultation, inviting feedback from members to inform the NFU's response. 

We also published our initial response which you can read below.

Initial NFU response

Our initial, high-level response to the environmental targets proposals and the Green Paper were included in the briefing document. The key points included:

• British farmers are passionate about maintaining and enhancing our countryside; providing a variety of habitats to support wildlife and plant species, protecting watercourses and reducing emissions.
• It is important that any future framework for nature and new environmental targets are flexible in meeting the needs of and delivering for both agriculture and the environment and sit alongside equally ambitious plans for domestic food production and UK food security.
• To ensure the success we all want to achieve through these new proposals, Defra needs to recognise the important role farmers and growers play. Ongoing engagement with farming is crucial throughout this process, as is linking with the new Environmental Land Management schemes where appropriate.
• Moving forward, any proposed changes need to be pragmatic and practical for farmers, and crucially based on science and evidence.

More specifically, our view is that any new targets must:

• have a clear evidence base for inclusion
• have a clear baseline
• be achievable, measurable and affordable
• have the right supportive policy mechanisms in place.

We believe that any new targets must consider the current landscape in which we are working and the ability of farming to deliver.

Defra's consultation on environmental targets opened on 16 March.

It was published alongside its Green Paper on Nature Recovery, which sets out proposals to restore nature and halt the decline in species abundance by 2030.

Representatives from the NFU took part in a roundtable discussion with the Defra Secretary of State, George Eustice, on the Green Paper and the new environmental targets consultation on the day of the consultation launch.

Long-term targets

The Environment Act requires the government to set, review and meet long-term environmental targets for air quality, water, biodiversity and resource efficiency and waste reduction. In addition, the government must set a species abundance target by 2030. It also requires targets to be set for fine particulate matter (PM2.5).

Defra consulted on a suite of targets in these areas. In addition, it also consulted on a tree-planting target. 

Agriculture

The proposed targets of particular interest to agriculture include:

• Halt the decline in species abundance by 2030.
• Increase species abundance by at least 10% by 2042, compared to 2030 levels.
• Create or restore 500,000ha of new wildlife-rich habitats, outside of protected sites, by 2042.
• Reduce nitrogen, phosphorus and sediment loss from agriculture to the water environment by at least 40% by 2037.
• Increase tree canopy and woodland cover in England from 14.5 to 17.5% by 2050.
• Reducing concentrations of fine particulate matter (PM_2.5) by 2040.