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Overview

This survey is to gather views and ideas about how to set successful environmental targets under the Environment Bill, to share with the government. It is particularly aimed at those who will be involved in helping to meet the targets, whether in business, professions, local authorities, environmental groups, government bodies or more widely in the community. It can be completed in approx. 5 minutes unless you want to provide more detail.

The results will be discussed at an event with the Environment Secretary, George Eustice in the morning of 23 September 2020 and fed back to ministers and relevant government departments. Please register here if you’d like to join the event.

For background, see the Government’s policy paper on how it will set environmental targets, IEMA’s primer on the Environment Bill or the Bill itself. See after the questions below for a brief summary of the Government’s targets proposals and of the Broadway Initiative work on targets.

The following questions draw on initial dialogue with business and other stakeholders. Please share your views to help inform the Government’s thinking on the targets.
Section 1: Scope of the targets framework

The policy paper sets out the Government’s initial objectives for the four priority target areas: air quality; water; biodiversity; resources and waste.

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* 1. Do you support the Government’s initial objectives for the targets?

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* 2. The paper explains the Government’s desire to develop targets that will drive action in areas that matter most, rather than limiting targets to areas that are easy to measure and improve. For example, it identifies improving soil health and woodland cover as potential candidates for additional targets. 

Are there additional targets the government should consider either at this stage or later?

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* 3. Do you agree, in principle, that where substantial improvement in an environmental outcome is needed, that a target, assuming well-designed, is helpful to facilitate a planned approach?

Section 2: Coherence of the targets framework.

One of the issues repeatedly raised in discussion so far is around coherence, both between the new targets and with the existing landscape of targets, for example the targets under the EU Water Framework Directive, the Air Quality Directive and the Marine Strategy Framework Directive. Issues raised, amongst others, include: linkages between the outcomes (for example water and biodiversity), that some activities for example reducing waste can affect multiple outcomes simultaneously and the need for better alignment of target timeframes.

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* 4. How important is coherence between target outcomes, including new and existing targets?

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* 5. The policy paper emphasises the importance of taking a systems approach to help join up related issues.

Do you think the Government should consider practical opportunities to set targets that join up related issues for example between carbon reduction and resource efficiency or between water and biodiversity?

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* 6. Linked to coherence, it has also been argued that transparency of the full set of targets is important so that for example, other parts of government, local authorities and business see the full set of targets that need to be met and can align their activities with them.

How important do you think transparency of the targets is to inform the following:

Government and regulators

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* 7. Local authorities

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* 8. Decisions of organisations such as businesses

Section 3: Translating outcome targets into activity-specific objectives.

The policy paper states that, where possible, targets should be based on outcomes in terms of the final results or benefit to the environment. An ‘outcome’ target (for example to improve quality of the air we breathe) is distinct from an ‘activity’ or ‘performance’ target (such as to reduce vehicle emissions). Discussion so far suggests that outcome targets can give an early signal that policy will go in a particular direction but that businesses and others need more granular detail about their responsibilities in meeting targets. This is especially the case where several sectors contribute to an outcome and it is unclear who needs to do what.

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* 9. Do you agree that it is important to give business more clarity about their responsibilities in meeting outcome targets?

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* 10. Do you support establishing objectives and pathways at least for those activities expected to make a major contribution?

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* 11. Some have suggested that interim targets may be one mechanism for setting activity pathways.

Do you agree that interim targets could be used to set activity level objectives?

Section 4: Link with the climate change target.

The Government has committed to a target of net zero emissions by 2050 under the Climate Change Act. The government has made this target a particular priority and is working to ensure plans are in place to meet it, especially in the context of the COP26 conference in November 2021. Other aspects of environmental action are often positively interlinked with climate such as resource efficiency and planting trees to offset carbon emissions. Whereas some actions could be good for one aspect of the environment but bad for another- for example, switching to diesel from petrol cars helped mitigate climate change but increased local air pollution.

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* 12. From your perspective, how important is it to consider wider environmental targets while planning to meet the net zero target?

Section 5: Establishing a target setting cycle.

This first suite of targets has to be set by 31 October 2022. The Secretary of State can set additional targets at any time. Initial dialogue suggests that the Government should establish predictable timelines for setting future targets, like the pattern of setting carbon budgets. This could be in line with the cycle for producing Environmental Improvement Plans so there is a plan to accompany targets.

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* 13. Do you agree the government should establish predictable timelines for setting future targets?

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* 14. If so, should that be on a 5 year cycle in line with Environmental Improvement Plans?

Section 6: Establishing a roadmap for targets.

Beyond the first suite of targets, future targets might for example be set for issues where significant improvement is needed but metrics aren’t ready by 2022 and where existing targets run out (for example Water Framework Targets beyond 2027 or air emissions ceilings by 2030). Some have suggested that it would be helpful if the Government produced a roadmap as an early signal of what targets it anticipates setting in the future and when. This could give the economy more certainty especially as target expiry dates approach. It could also help the Government plan for a more coherent set of targets longer term rather than being restricted to filling gaps in the legacy of targets. The roadmap could be updated annually in the Environment Bill’s cycle of performance reports.

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* 15. How important is it to give a longer term indication of what targets the government anticipates setting in the future?

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* 16. Specifically, would it be helpful if the government developed a roadmap?

Section 7: International alignment.

Some have argued that it is important to set targets that align with or set the international direction, particularly because of the international nature of both environmental challenges and of economic markets. The Sustainable Development Goals are often mentioned as a potential framework for setting national targets on the environment.

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* 17. How important is international alignment?

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* 18. Should the Sustainable Development Goal framework be used to help guide the targets?

Section 8: Setting the right target level.

The level of ambition of targets is guided by two requirements in the Environment Bill 1) the Secretary of State must be satisfied that targets can be met and 2) the Secretary of State has to review targets to see if they would significantly improve the environment (assuming the targets are met). Within those parameters there are different approaches to setting the target level, with different assumptions for example about the degree of innovation achievable. One approach is to be more cautious about the level of innovation possible and then ratchet the target level up as new technologies emerge. For example the climate change target was changed from 80% to 100% in net terms. Another approach is to make more stretching assumptions about innovation from the start.

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* 19. Which of the following approaches would you prefer to setting the target level?

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* 20. Section 9: Other success factors.

In your experience are there other factors that have been important in determining the success or failure of targets in the past? Please share examples.

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* 21. Section 10: About you.

What type of organisation do you represent?

Summary of the Government’s targets proposals. 

Briefly, the government must by 31 October 2022 set at least one target in each of four priority areas: air quality, biodiversity, water, and resource efficiency and waste reduction, as well as a target for fine particulate matter (PM2.5). The government can set additional targets at any time.

Last month the government published its policy paper on how it will set environmental targets under the Environment Bill. In it, the Government explained the process for setting targets including the criteria to set targets, the scope of targets and sources of target evidence and how you can get involved. The paper also set out the government’s initial objectives in each of the four target areas: 
  • Air quality: reducing the annual mean level of fine particulate matter (PM2.5) in ambient air; in the long-term, reducing population exposure to PM2.5
  • Resource efficiency and waste reduction: to increase resource productivity and reduce the volume of residual waste we generate.
  • Biodiversity: improve the quality of habitat on land, including freshwater and coastal sites, expressed through the condition of our protected sites (SSSIs); improve the quality of our marine habitat, expressed through the condition of Marine Protected Areas; improve the overall status of species populations on land and in freshwaters; restore and create wildlife-rich habitat outside protected sites through appropriate management.
  • Water: reduce pollution from agriculture, in particular phosphorus and nitrate; reduce pollution from wastewater, in particular phosphorus and nitrate; reduce water demand.
For more background on the targets, see the IEMA primer on the Bill or the Bill itself. 

Summary of Broadway’s work on targets 

The Broadway Initiative, an alliance of business organisations working with professional and environmental groups, did substantive engagement with the business and wider stakeholder community to offer advice on the inclusion of targets in the Bill, including a large participatory event at the QE2 centre in London. That work found that well designed targets can help all parts of the economy and society to plan and invest to help meet the government’s commitment to leave the environment in a better state, alongside the government’s target for net zero greenhouse gas emissions. See here for advice Broadway provided to inform the design of targets in the Bill. The purpose of this survey is therefore to help inform the design of targets.
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