In a move welcomed by green groups as “a good start”, Defra published proposals to set legally-binding environmental targets for England, to be achieved by 2030. These will be in the areas of air quality, water quality and management, waste and resources, and biodiversity. In this article, Caroline Hand focuses on the areas of most relevance to business.
The Environment Bill requires the Government to set at least 1 target in each of the 4 priority areas. Defra’s paper, Environment Bill — Environmental Targets, published in August 2020, suggests 18 possible targets. The Government will investigate and develop these targets in partnership with experts, produce a socio-economic analysis of the targets, and then launch a public consultation in early 2022.
Statutory instruments to bring the targets into law will be brought before Parliament by 31 October 2022. The intention is that the targets should work together for the overall benefit of the environment, for example, by setting water quality targets that also help deliver biodiversity objectives.
Environment Secretary, George Eustice, has made it clear that the target-setting process will rely on expert scientific input. He has commented that it may be better to set a larger number of more specific targets, rather than general overarching goals which may prove impossible to achieve.
The recommended air quality targets relate to fine particulate matter (PM2.5), the pollutant thought to have the most serious effects on human health. Long-term exposure is linked to a number of health impacts, including respiratory and cardiovascular disease, cancer and dementia.
Defra have proposed two kinds of target for PM2.5.
A reduction in the exposure of the population as a whole.
A lower concentration limit (as already required by the Environment Bill).
The Defra paper does not set numerical limits. The Government considers that further analysis is needed “to set the level of ambition as well as to understand how [targets] can be achieved”.
This target would aim for continuous improvement across the whole country, ensuring the action taken is effective in maximising public health benefit. The UK already has an obligation to reduce average exposure by 15% (from 2010 levels) by the end of 2020.
Air quality campaigners have long pressed for adoption of the World Health Organisation (WHO) recommended concentration limit of 10µg/m3 and have been disappointed that neither the Environment Bill nor the Defra paper commit to this. Though Defra says that it is technically feasible to achieve the WHO standard, it would be difficult to achieve, particularly since much of the PM2.5 in England’s air originates on the continent. The current concentration limit is 25µg/m3- well above the WHO recommended value.
Air quality campaigners would also like to see targets extended to other pollutants, particularly nitrogen oxides (NOx). England regularly exceeds the statutory limits for NOx, due to high levels of pollution in London and other urban centres.
Recent research by the CBI’s economic analysis arm on behalf of the Clean Air Fund, What is the Economic Potential Released by Achieving Clean Air in The UK? predicted that improving air quality in England in line with WHO guidelines could deliver a £1.6bn economic benefit, while preventing 17,000 premature deaths each year. The financial benefit would be achieved by reducing premature deaths and sickness absence from work and improving productivity. This does not include the gains to the NHS through having fewer patients to care for. Improving air quality in London alone would provide an economic benefit of almost £500m annually. Commenting on the findings, London’s Mayor Sadiq Khan said that “I am doing everything in my power to stop Londoners breathing air so filthy that it damages children’s lungs and causes thousands of premature deaths”.
New targets for water quality could seek to reduce the concentration of pollutants — particularly nitrates and phosphates — in wastewater. The publication of the proposed targets coincides with the announcement that none of England’s rivers have met the requirements of current legislation, which is derived from the EU Water Framework Directive. There is fear amongst some groups that post-Brexit water quality standards set by the EU could possibly be dropped and replaced with less stringent ones.
Other suggested targets would focus on the sustainable management of water resources. At present, 21% of public water supply is lost in leakage. A target could be set to reduce the volume of water distributed or abstracted by water companies. This could reflect both leakage and per capita consumption.
Waste and resources
Two waste-related targets have been proposed, both of which link to the Waste and Resources Strategy for England.
The first is to reduce England’s residual waste (ie waste that is not reused or recycled) by 20%. In 2018, more than 11 million tonnes of municipal waste went to landfill in England and over 50 million tonnes of total waste (ie including industrial waste) went to landfill or incineration. The total residual waste rises if we include the three million tonnes of waste that is exported to other European countries in the form of refuse derived fuel (RDF).
The second target under consideration is to increase resource efficiency. Resource productivity measures the economic value per unit of raw material use. The 25-Year Environment Plan and Waste and Resources Strategy already include aspirations to achieve zero avoidable waste and double resource productivity by 2050. Defra says it will “review the level of this ambition based on the evidence, to establish what a legislative target could be.”
These proposed targets have been welcomed by the waste and resources industry. Pat Jennings of the Chartered Institution of Wastes Management (CIWM) has suggested that Defra could go further and include a “circular economy” target which would seek to prolong the life of resources in productive use. England could follow the example of Japan, which in addition to indicators for resource productivity and waste to landfill, has an indicator for the cyclical use rate of materials in the economy. This is calculated as material reused as a proportion of total material used.
The remaining proposals for targets concern the natural environment and biodiversity. Defra’s paper gives a long list of possible targets covering a wide range of issues, including wildlife conservation, marine protected areas, soil quality and woodland cover. From a business perspective, these targets could be effective in channeling private sector investment into projects that drive environmental improvement.
Once the targets have been made law, the new Office for Environmental Protection (the independent environmental watchdog) will hold the Government to account by reporting annually on the progress in implementing them. The targets will apply to all future governments.
So far, the response to the proposed targets has been positive. For example, the Aldersgate Group’s Public Affairs Manager, Signe Norberg, said that “If designed correctly, these targets will provide much needed long-term policy direction to businesses, shape environmental policies in the decades to come, and drive private sector investment in the natural environment”.