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PTES response to the ‘Consultation of environmental targets’ (England) in relation to Sections 1-3 of the Environment Act 2021

Home // News // PTES response to the ‘Consultation of environmental targets’ (England) in relation to Sections 1-3 of the Environment Act 2021

27 June 2022

People’s Trust for Endangered Species (PTES), a UK conservation charity created in 1977, is ensuring a future for endangered species around the world. PTES protects some of the world’s most threatened wildlife species and habitats, and provides practical conservation support through research, grants, educational programmes, wildlife surveys, and publications. PTES’ current priority species and habitats include hazel dormice, hedgehogs, water voles, noble chafers, stag beetles, traditional orchards, native woodlands, wood pasture and parkland and hedgerows.

With the implementation of the Environment Act, the government rightly seeks to create world-leading legislation that will protect and enhance our environment for future generations, by halting the decline of species and increasing biodiversity. As part of the act the implementation of biodiversity targets is welcomed, particularly the twin targets of preventing extinctions and recovering species abundance. With COP15 on the horizon, this is an opportunity for the UK government to establish unparalleled standards that will provide leadership to the international community as new and ambitious CBD targets are agreed.

Whilst the proposed terrestrial biodiversity and freshwater targets set out in the consultation provide a (broad) basis from which to work, they need to be in line with the Lawton principles of bigger, better, more and joined up to ensure that provision of new and improved habitat is targeted so it can drive ecological recovery, supporting the species abundance and extinction targets. The current proposals lack sufficient ambition and scope to fully address the current biodiversity crisis. In response to the biodiversity targets (for England) consultation, please find below our key concerns and recommendations:

Species abundance target

  • The proposed baseline for the species abundance target and recovery target of 10% on 2030 levels by 2042 are not sufficiently ambitious and risk resulting in lower biodiversity levels than we have today.
  • A baseline of 2022, in line with other proposed Environment Act targets, should be adopted with a higher target of at least 20% – in line with ambitions being set by the CBD – to ensure our nature is on course to recover by 2050.(1)
  • The species proposed to represent England’s biodiversity within the species abundance target is too narrow and falls short of representing all key taxonomic groups leaving key habitats, such as wetland, not being represented by flagship species, such as amphibians.
  • To fully inform and support the Nature Recovery Green Paper ambitions, targets must be clear, informative and as over-arching as possible and include a fuller suite of species from across taxonomic groups, in order to fully measure efforts to restore ecosystems, that are fully functioning biologically, within different habitats.
  • Risks in using limited datasets are likely to result in ambiguity in the indicator. Relying on a limited list of species has the potential to introduce selection bias if trends in species included are not random with respect to the ‘population’ of species the indicator is supposed to represent(2). Meaningful trends can easily be missed if, for example, increases in opportunistic species mask the loss of other species(3). Biases introduced by over-representation of well-studied and monitored groups have been shown to underestimate declines.(4) For example, caution should be taken before including species with limited ranges (whose decrease or increase may severely skew the trend) or reintroduced species (such as beaver and pine marten, where marginal increases in relatively short periods will bias the index).
  • Opportunistically collected data, including those gathered by citizen scientists, can accurately produce trends gathered from more structured surveys(5) and provide the opportunity to elicit more precise information to improve the robustness of trends(6). We are lucky to have a history of genuine interest in the natural world and a general public willing to engage as citizen scientists. Our recording schemes and public engagement are the envy of countries around the world. Incorporating opportunistically collected data on a broader group of species offers a chance to assess the overarching target using two complimentary datasets: robust population abundance data and a broader set data, which can be analysed with occupancy modelling techniques, to calculate trends which represent changes in distribution (occupancy) as a proxy for abundance trends(7). These can then be presented as two distinct but parallel indexes, covering a wider group of important taxa which will enable new habitat targets to be more effectively monitored and measured. This proposal offers the chance to address the poor representation of some important taxa in the indicator, such as the limited number of marine species, the absence of pollinators apart from Lepidoptera, and key indicators of ecosystem health such as amphibians.
  • It is also important that the index is accompanied by a full breakdown by key taxonomic group, species, habitat type and at different functional spatial scales, supported by local case studies.
  • Indicator species should be included that raise the alarm when they disappear or decline below a particular threshold.
  • There is insufficient representation of the marine environment within targets; it is recommended that separate marine abundance/occupancy indicator are developed, as is the case in Scotland.
  • All the above recovery targets must be supported by ample resources to fully achieve the ambitions of the Act.
  • With COP15 on the horizon, this is an opportunity for the UK government to establish unparalleled standards that will provide leadership to the international community as new and ambitious CBD targets are agreed.

Extinction risk target

  • We welcome the inclusion of an extinction risk target but feel the current proposal to improve the England-level GB Red List Index (RLI) by 2042, compared to 2022 levels, is flawed because it lacks any detail regarding what levels of improvement are required, how any measurements will be undertaken and does not include interim milestones.
  • A fully quantifiable target is needed and we recommend a target to reduce the extinction risk to species by at least 30% by 2042 compared with 2022 levels.
  • It is also important to consider and account for weighing up the number of species whose status is improving compared with the number of species which are still declining. We need to ensure a successfully achieved extinction target does not mask declines in suites of species reliant on overlooked habitats.
  • It is also important to note that the sensitivity of the proposed England-level GB Red List Index to measure possible change in extinction risk is unknown on this timescale and that there is currently no detail on the cost and feasibility of the proposed exercise, including those of expert assessor support and conducting decadal Red List assessments.
  • Caution is also required in using the Red List whereby a population declining by the same proportion each year will never qualify for higher threat category under criterion A, even as it goes extinct, but must instead qualify under the other criteria B-E(8). A population in chronic decline does not fit with the declining species paradigm(9). This is particularly important for species such as hazel dormice (Muscardinus avellanarius) which have short generation lengths coupled with low productivity and are unable to recover from population slumps as quickly as may be expected for R-selected species(10). Rather than relying on changes that are not sensitive enough for Red List criteria, other measures can and should be incorporated into an extinction risk such as the concept of Favourable Conservation Status (FCS). FCS is able to account for chronic declines: any amount of population decline >1% per year is considered Unfavourable(11). Its other benefit is that instead of focussing on proximity of extinction, FCS can be used in prioritising species in need of conservation before declines in their numbers become too critical and costly(12).

Habitat target

  • We believe that the creation of 500,000 hectares of wider habitat lacks the ambition to align with the 25 YEP and 30×30. The current proposal represents just 4% of England’s land. A greater ambition of at least 750,000ha should be adopted, supported by nearly 70% of participants in Defra’s development workshop. The creation and restoration of new habitats needs to be carried out and measured alongside any loss or degradation of existing habitats. And the designation of areas needs to be targeted; it might be that certain habitats are identified through the new local recovery strategies.
  • There are inherent pitfalls in habitat creation and restoration targets that treat all habitats as having equal value by area. Biodiversity metric 3 does not place a higher unit cost on habitats that have a greater density of biodiversity. For example, a hectare of traditional orchard or mile of hedgerow will host a far greater diversity and abundance of species than an equal area of upland heathland or coastal mud flat. Detail is required on how this will be accommodated in habitat creation and restoration.
  • Habitats that may be easier to create could account for the bulk of the creation and restoration effort at the expense of those that may be more biodiverse but difficult to create or maintain in the longer term.
  • We think certain habitat types should be excluded, for example non-native (broadleaved woodland is included in the list of medium-distinctiveness habitats but there is no specification that it should be native) and short-lived habitats (such as arable field margins). There also needs to be consideration given to which areas outside the protected area network are key to recovering populations of widespread but declining species.
  • Whilst the creation and restoration of new habitat is welcome, there is currently no outcome target focussing on the condition of habitats in England already protected with designated sites; the majority of our SSSIs are in poor condition but without their restoration, species recovery targets will not be met.
  • We recommend inclusion of a target ensuring at least 75% of SSSIs are in favourable condition (in England) by 2042, with the remaining 25% showing signs of recovery.

PTES’ datasets

PTES runs several monitoring programmes that gather sufficiently robust data but have currently been excluded from the species abundance index. The National Dormouse Monitoring Programme (NDMP) has been running since the 1990s and contains data from ~400 sites that are monitored at least twice annually. The National Water Vole Monitoring Programme (NWVMP), established in 2015, contains useful data from over 100 sites. Power analysis shows it should be possible to detect trends using occupancy models. PTES has also supported annual surveys on the only English mountain hare population in the Peak District for the past five years, which has seen the collection of robust data.

There is clearly scope for including data on more mammal species with the species abundance index than is currently proposed. These species are critical, in that they are at risk mammals, unable to easily move to new habitat, and more fully representative of our terrestrial species than bats. Whilst bats are important, the fact that they occupy similar ecological niches makes them unrepresentative of mammals more widely. Current increases in populations of lesser and greater horseshoe bats are particularly marked which could result in the trend being influenced by species with relatively restricted ranges (southern England) Boughey and Langton 2021.(13)

PTES also works on priority habitats, including traditional orchards and hedgerows. PTES created the Traditional Orchard priority habitat inventory and assessed its conditional on a national level. This created a baseline that can be used to make future assessments of improvements or further habitat decline. Data is also being gathered on hedgerows using a heath-check survey which provides condition assessment and advice on ways to restore the habitat.

PTES looks forward to supporting and working with Defra in the coming months, providing data and developing robust, ambitious targets that will prevent any further declines in species populations, or in quality and extent of habitat, and set the course for the recovery of our biodiversity.

We hope this response provides some useful advice and recommendations that will enable us to work together as a wider community to ensure protection and recovery for the UK’s species, both in and outside protected areas.

PTES is part of Wildlife and Countryside Link (Link), the largest environment and wildlife coalition in England, bringing together 65 organisations to use their strong joint voice for the protection of nature. Together Link provided a fuller response to the biodiversity targets, as well as water, air quality, resource efficiency and waste reduction which can be downloaded here or accessed here:


1 IUCN, Post-2020 global biodiversity framework.
2 Magurran, A.E., Baillie, S.R., Buckland, S.T., Dick, J.M., Elston, D.A., Scott, E.M., Smith, R.I., Somerfield, P.J. and Watt, A.D., 2010. Longterm datasets in biodiversity research and monitoring: assessing change in ecological communities through time. Trends in ecology & evolution, 25(10), pp.574-582.
3 de Heer M, Kapos V & ten Brink B.J.E 2005 Biodiversity trends in Europe: development and testing of a species trend indicator for evaluating progress towards the 2010 target Phil. Trans. R. Soc. B360297–308
4 McRae L, Deinet S, Freeman R (2017) The Diversity-Weighted Living Planet Index: Controlling for Taxonomic Bias in a Global Biodiversity Indicator. PLoS ONE 12(1): e0169156.
5 Bradter, U., Mair, L., Jönsson, M., Knape, J., Singer, A. and Snäll, T., 2018. Can opportunistically collected Citizen Science data fill a data gap for habitat suitability models of less common species?. Methods in Ecology and Evolution, 9(7), pp.1667-1678.
6 Boersch-Supan, P.H. and Robinson, R.A., 2021. Integrating structured and unstructured citizen science data to improve wildlife population monitoring. bioRxiv.
7 van Strien, A.J., Meyling, A.W.G., Herder, J.E., Hollander, H., Kalkman, V.J., Poot, M.J., Turnhout, S., van der Hoorn, B., van Strien-van Liempt, W.T., van Swaay, C.A. and van Turnhout, C.A., 2016. Modest recovery of biodiversity in a western European country: The Living Planet Index for the Netherlands. Biological Conservation, 200, pp.44-50.

8 Mace, G.M., Collar, N.J., Gaston, K.J., Hilton‐Taylor, C.R.A.I.G., Akçakaya, H.R., Leader‐Williams, N.I.G.E.L., Milner‐Gulland, E.J. and Stuart, S.N., 2008. Quantification of extinction risk: IUCN’s system for classifying threatened species. Conservation biology, 22(6), pp.1424-1442.
9 Caughley, G., 1994. Directions in conservation biology. Journal of animal ecology, pp.215-244.

10 Turbill, C., Bieber, C. and Ruf, T., 2011. Hibernation is associated with increased survival and the evolution of slow life histories among mammals. Proceedings of the Royal Society B: Biological Sciences, 278(1723), pp.3355-3363.
11 JNCC (2019). European Community Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora (92/43/EEC): Fourth Report by the United Kingdom under Article 17 on the implementation of the Directive from January 2013 to December 2018. Conservation status assessment for the species: S1341 -Common dormouse (Muscardinus avellanarius). Technical report.
12 Scopes, E., Goodwin, C., Al-Fulaij, N., White, I., Langton, S., Walsh, K., Broome, A. and McDonald, R., 2022. Shifting baselines for species in chronic decline and assessment of conservation status. Are hazel dormice (Muscardinus avellanarius) Endangered? Unpub.
13 Boughey K, Langton S. 2021. UK Biodiversity Indicators: Technical Background Document. https://data.jncc.gov.uk/data/5299ab4d-c442-4e20-880e-b651297cb579/ukbi2021-techbg-c8-a.pdf

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