Government’s consultation on setting legally-binding targets under the Environment Act (2021) is an opportunity to create much clearer direction for the environment over the long-term. IEMA’s Policy and External Affairs Director, Martin Baxter, outlines key issues raised in IEMA’s response which was informed through widespread engagement with members, as well as dialogue with Defra policy officials and key stakeholders.


The Environment Act (2021) requires government to set at least one long-term legally binding target in each of the areas of biodiversity, water, air quality, and resource efficiency and waste by the end of October 2022. In addition, the Act sets a 2030 target to halt the decline of species abundance and requires government to set an ambient PM2.5 air quality target. In total, Defra’s consultation proposed 13 legally binding targets.


Setting the first legally binding targets under the Environment Act is an opportunity to create much clearer direction for the environment. As well as providing the framework for national policies, it is also an opportunity to galvanise action and investment from businesses, towns, cities, NGOs and the public towards a common set of environmental outcomes.

The net zero legally binding target, because of its clarity, is beginning to create that self-generating momentum, within a framework of government policy and regulation. City regions to whole sectors and individual businesses are creating their own targets enabling them to lead and design necessary change and sequence cost-effective investment reflecting their own circumstances.

In contrast, the current situation in terms of the wider environment is that businesses and localities develop their own initiatives generally unconnected with national policies because, historically, government has never been clear or robust on our shared national goals and targets.

While many of the individual environmental targets set out in the consultation are well conceived, overall they miss the wider opportunity. IEMA highlighted that with a small number of focussed improvements, the proposed targets could hit the mark in a way that would galvanise greater support for delivery. In summary this would mean setting the proposed targets within a clearer overall architecture, with:

  1. The inclusion of “apex” targets for water and resources & waste, alongside those for nature, air and net-zero carbon emissions. This will give outcome targets for the whole of the environment that everyone can relate to, and provide a coherent framework for setting attribution and activity based targets which contribute to the overall outcomes.

  2. Alignment of target end dates to decadal intervals, making the targets easier to communicate and to align programmes of work (e.g. for nature and water to take joined up action). Defra’s proposed target end-dates are 2030, 2037, 2040, 2042, 2050 – we believe this makes it unnecessarily confusing for businesses and others to relate to.

  3. A target for the status of protected sites should be included, given that Defra acknowledge this as critical to achieving the species abundance target.

  4. A clear roadmap for the introduction of additional targets (including for soil and construction waste) and the refresh/update of existing legally binding targets.

Following evaluation of the consultation responses, Government will publish draft regulations by the end of October 2022, which will be debated in Parliament before coming into law. Thereafter, the first statutory Environmental Improvement Plan (EIP) will be the crucial opportunity to evolve the Government’s 25 Year Environment Plan from a high-level vision into a clear strategy underpinned by specific interim targets and specific sets of policy measures. Meaningful stakeholder engagement in the coming months on the development of the EIP will therefore be crucial, as will consideration of the skills and workforce requirements to deliver on the ambition.

IEMA will continue to engage with government to help translate ambition set through the targets into action. You can read IEMA’s full response to the consultation here.

Photo of Martin baxter
Martin Baxter FIEMA, CEnv

Executive Director - Director of Policy & External Affairs, IEMA

Martin works in the UK and internationally to support the transition to a low carbon, resource efficient and sustainable economy.

Martin leads IEMA’s policy and external engagement activity with government and business. A strategic thinker with the capability to lead and influence others, he has national and international experience in developing and negotiating global and European standards and developing capacity for effective and widespread implementation. Martin is head of the UK delegation to the International Organisation for Standardisation (ISO) on environmental management and chairs the ISO environmental management systems committee of ~100 countries.

Martin has experience of networking and communicating at all levels – including with senior parliamentarians, Government officials, business leaders and academia. He is an acknowledged expert on environmental management and a regular spokesperson on corporate sustainability.

Martin is a Board member of IEMA and the Society for the Environment (SocEnv).