OEP CEO Natalie Prosser was a keynote speaker at the Westminster Energy, Environment & Transport Forum event held on 27 February 2024. The conference examined next steps for environmental protection and standards in the UK, and the role of the Office for Environmental Protection.
Natalie Prosser's speech can be found below:
Good morning and thank you for inviting me to speak at such an important event. I was delighted to be asked as this allows me to talk to you all about our findings from our recently published EIP progress report.
But before I do so, I would like to put in context the scale of the challenge that we all face in order to secure the much-needed improvement in our natural world that is clearly required.
I would like to start by reflecting government’s long-stated ambition to be the first generation to leave the environment in a better state than it was found. In his introduction to the revised Environmental Improvement Plan of January 2023, the Prime Minister recognises that protecting the environment is fundamental to people’s health and prosperity. The scale of the challenge, in his words, means “changing the trajectory that the country has been on ever since the industrial revolution”. Those words signal the nature and scale of what is to be done, and its criticality. It is not a choice, but a necessity, to protect the nation’s health and prosperity. And for us to be responsible stewards of our environment.
Many of you, if not all, will be familiar with the 2021 Environment Act, in which Parliament put in place four cornerstones for environmental governance: The Environmental Improvement Plan, or EIP, sets out how government intends to improve the natural environment.
Second are statutory targets, to which government is now legally committed, and which set the specific states and timelines for improvements to be made.
Third is a new Environmental Principles Policy Statement, to which all public authorities must have regard when making their decisions.
Finally, the fourth cornerstone is the Office for Environmental Protection, established to make sure that this new system works, that the environment is improved as Parliament and government intends, and in line with legal obligations.
If these cornerstones are implemented effectively, and each fulfils its purpose as intended, it will create the opportunity for government to achieve its ambition to leave the environment in a better state for future generations.
But things are never that simple, are they?
One of our most important jobs, one of our statutory roles, at the OEP is to report on how well the EIP is working on delivering the government’s commitments. And to judge progress towards meeting the legal targets. We published our latest annual assessment of progress in January. It is on our website and I do encourage you to have a look.
In short, we conclude that government is largely off track, and must speed-up and scale-up its activities, and make sure that its plans stack up in way that ensures its targets are met.
And when I talk about stacking up, what I mean is that we need to understand how the range of actions that the government is taking will work together to achieve what are ambitious and demanding targets. And we need to know who is going to be delivering on those actions, at what scale and by when. After all, it is all in the doing.
This brings me on neatly to effective implementation – which is a consistent and dominant theme that runs through our work. The need to turn plans and ambitions into actions and measurable achievements.
As a nation, we must do better, if we are to turn around the critical negative environmental trends that currently persist.
But it can be done. It is our assessment that we have not yet reached the tipping point beyond which the decline is not irreversible. The ambitious targets set by government can still be achieved and we understand the science well enough to know how.
And being here this morning, it is so heartening to speak to you, those who have such a crucial role to play and who can, and are committed to, making the difference.
This time last year, our report’s headline was that progress had fallen far short of what was needed to meet government’s ambitions. Less than a third of the environmental trends we then monitored were moving in the right direction. This year we report that almost half of the 51 trends we now track are moving in the right direction, with positive trends within each of the ten goal areas of EIP23.
For example, water leakage in England is reducing. The number of illegal waste sites has reduced, albeit new ones are being found all the time. The percentage of fish stocks that are sustainably harvested has increased since the early 2000s. There are fewer tree pests and diseases becoming established than has been the case historically.
But we find that in the clear majority of the ten goal areas of the EIP23, progress has been mixed.
So, with a half of trends moving in the wrong direction, or not moving, or not readily or not yet assessable, the question we have been grappling with is this: overall, are trends and progress across the board and in each EIP goal area moving in the right direction fast enough and far enough, to meet statutory and other environmental targets and commitments and government’s wider ambitions?
We conclude (on the data and wider information available to us) that the chances of the recently established statutory targets for the environment being met are largely off-track, and government’s wider ambitions for our environment are not likely to be met unless things change.
But these prospects are not set in stone. Things can change. As I have said, and as our stakeholders have told us, the apex goal in the EIP (Thriving plants and wildlife) and targets are still achievable, and for every goal area we highlight many opportunities to improve prospects of achieving the targets. Standing back from the detail, the message we have are clear.
So, first of all, government must speed up its efforts. As we detail in our report, too many policies are still in the early stages of development – Marine Net Gain and Fisheries Management Plans for example - or else are just long awaited, like the Land Use Framework. In one or two goal areas – Managing exposure to chemicals and pesticides, for example - thinking and action are far behind the curve, the situation is not resolvable quickly, and significant programmes of work are needed.
In some goal areas, however, enough of the right policies are already on the books. They now need to be implemented, quickly and fulsomely.
We think that is the case for the legally binding targets of first halting and then reversing the decline in species abundance, for example.
Our view is that completion and delivery on the ground of established policies must go faster, to meet the pressing needs of the environment. So, government must speed up its efforts.
Secondly, government must scale up its efforts. Change has to happen at the right scale, if we are to change the trajectory. We give many examples in our report where scaling up is required. It is a prevalent theme: government must speed up AND scale up its efforts.
We particularly highlight here the importance of nature-friendly farming if government is to meet its goals for thriving plants and wildlife, and clean air and water. Farmers are being asked not just to produce much of our food but to modify how they farm, for the sake of our future health and prosperity. It is critical now that enough farmers and landowners step up to the plate. Earlier this month government announced increases in the payments to be offered for good land management, three-year deals for tenant farmers and a streamlined application process. We will watch progress keenly here, because so much is at stake.
Lastly, government’s plans must stack up. Government must be clear itself and set out transparently how it will change the nation’s trajectory to the extent now needed, in good time.
We need clarity on what we need to do to play our part in order to make this change happen.
Farmers, landowners, industry, environmental groups, local authorities, other delivery bodies, the wider public – and you, here in this room - will rise to the challenge if they can see what must be done, and what they each must do.
If they can see it can be done, and that if we speed up and scale up, we can change the trajectory. If they can see that taken together, government’s plans stack up, and it is clear all that must be done in each goal area, and against each statutory target, when, and by whom.
We do not have that clarity, that transparency as yet. Almost a year on from EIP23, we at the OEP find that hard to accept, when matters are so pressing. We believe it saps faith in the EIP itself and leaves key players hesitant and uncertain.
In our view, government must do better. It must set out transparently and fully for Parliament, the public, all those who must deliver and play their role, and yes also to us, the independent statutory oversight body, how it intends to deliver its ambition.
Effective implementation is the key theme from that report. And it comes across so strongly in other areas we have looked at.
We reported recently on the implementation of Environmental Assessment regimes relating to new developments. We have a keen interest in these regimes, as government has signalled an intent to change or reform them. There is significant opportunity in doing so, but also risk – as with any such changes.
We looked at the Habitats Regulations Assessment (HRA), Strategic Environmental Assessment (SEA) and Environmental Impact Assessment (EIA) to get a sense of what has been working well and what has not.
We found that the main barriers to the regimes not being as effective as they might be found in the implementation and delivery within the planning system, rather than in the regulations themselves.
There are three main themes that come across in our research. There are concerns about lack of ready access to relevant data; inadequacies in post decision monitoring, evaluation and reporting; and in public authorities’ access to necessary expertise.
And, while I have you here, I will look ahead to two other pieces of work we will be publishing soon, where again implementation will be key.
We are reviewing the law in relation to protected sites. They are so important if environmental targets are to be met, but recent decades have seen little progress in expanding the networks. We are looking in detail to get to the root of how the law here is being implemented, its effectiveness and, if appropriate, to recommend improvements. Our work is focused on Special Areas of Conservation and Special Protected Areas in England and Northern Ireland, Sites of Special Scientific Interest in England and Areas of Special Scientific Interest in Northern Ireland.
I also wanted to touch on the Environmental Principles Policy Statement, as I know many of you are interested. How powerful is it, and how welcome, that Ministers and government departments now have a new legal obligation to consider the impact their policies will have on the environment. This aims to put the environment truly and properly at the heart of all relevant policymaking in government. But the proof is in the pudding, as they say. We are watching and hope to report in due course on now this is being implemented, and the difference it is making.
Before I finish, I want to draw your attention to a report we have coming out before the summer representing the culmination of a significant piece of work. This is our biggest review yet on the implementation of environmental law, to protect the water environment, including water quality, in England and Northern Ireland. It is concerned with the Water Framework Directive Regulations in England and includes the implementation of these regulations through the latest round of River Basin Management Plans in England and Northern Ireland and underlying measures, such as nutrient management plans. It will build on and go further than our recent EIP report, which found progress on the goal of clean and plentiful water to be off-track. In this upcoming report we will examine our water bodies and the unsatisfactory condition they are in, and consider why this is the case.
Whilst we recognise and commend action that is being taken to drive some improvement, government and other public bodies need to urgently do more to protect the freshwater and coastal water environments.
We will be laying this report before Parliament – where we hope by commenting openly on the issues that exist – we will be highlighting critically needed measures to be taken - as a matter of urgency.
Conclusion
To conclude, changing the trajectory enough requires determination, detailed planning, forecasting, clarity and transparency, constant evaluation and a willingness to take some difficult decisions when necessary. Effective implementation. And it means doing more and doing enough quickly enough to get on track and keep on track. I hope that our work is useful to you as you fulfil your own roles to protect and improve the environment. We intend to play our part, as indeed I trust you will too.
