IEMA’s recommendations to Defra on Nature Recovery Green Paper

Defra’s consultation on the Nature Recovery Green Paper was launched in March of this year. IEMA held two member workshops which considered both this paper and the Environmental Targets consultation running concurrently. IEMA members who participated in the workshop represented sectors including coastal, housebuilding, and infrastructure.

The largest focus of the Green Paper was on amending the titles and structure of protected sites, potentially reorganising the arms-length bodies (ALBs) which might manage and report on them, as well as who will make decisions on protected sites - central government or ALBs. IEMA’s main concern was that, while reorganisation is not a bad thing, it should have a clear purpose and goal and not hinder immediate action that is needed to restore and enhance nature.

IEMA’s key points in the response are as follows:

• Changing the current regime for sites and species protection is irrelevant without having sites in a favourable condition, with relevant resources and enforcement to achieve this. Before any decision is made to reorganise the current regime for sites and species protection, the Government must consider the best outcomes for nature recovery and then identify how existing structures do not meet their current role in achieving this. IEMA offered to support this activity.
• The focus of 30/30 (30% of land under protection by 2030) should be on bringing protected sites up to a good standard including the creation of enhancement targets. 30/30 should focus on enhancing biodiversity and nature i.e. it must go beyond protection.
• Any reorganisation must not reduce the protection of sites or species, or the capacity (and resources) to achieve the necessary actions by ALBs to support business to restore and enhance nature.
• Investment in resources and skills is essential to the development of any effective site protection and enhancement regime and should be prioritised as part of any reorganisation.

Defra was also looking for more information on how to improve environmental impact assessments (EIAs) including in forestry, agriculture and marine. IEMA was able to direct Defra to several previous representations that IEMA has made on EIAs and recommended that EIA reform should be guided by the principles set down in the following analysis:

• Proportionate EIA – A Collaborate Strategy For Enhancing UK Environmental Impact Assessment Practice, IEMA 2017
• Levelling up EIA to Build Back Better, IEMA, 2020
• The Future of Environmental Assessment, 2020 (a report from IEMA to MHCLG and DEFRA)

The closing date for the Nature Recovery Green Paper consultation was 11 May 2022. For those who took part in the IEMA workshops on Defra’s consultation on Environmental Targets, it should be noted that the deadline has been extended (due to the late arrival of supporting information) to 27th June 2022.

IEMA’s full response can be found here.