AEF Response to Consultation on Environmental Targets

30th June, 2022

AEF has responded to a Defra consultation on environmental targets.

Under the Environment Act 2021, which was introduced post-Brexit, the Government is required to set at least one long-term target in each of the following areas: air quality; water; biodiversity; and resource efficiency and waste reduction, including specific targets for fine particulate matter (PM2.5) and species abundance. 

AEF has responded to three sections of the consultation: target proposals for biodiversity on land, long-term species abundance targets, and target proposals for air quality.  

Biodiversity on land and long-term species abundance targets

AEF supports the need for targets to protect biodiversity and increase  long-term species abundance. However, we have concerns about the Government’s proposed target to achieve this outcome. Aiming for a 10% increase in species abundance between 2030 and 2040 is not sufficiently ambitious given that “the average change in the England priority species index has been a decline of approximately 2% per year”. If this trend is allowed to continue until 2030, there is a strong likelihood that species abundance in 2041 will be in a worse state than it is today. The appropriate baseline year for the target should therefore be 2022, not 2030.

Higher levels of ambition for biodiversity are perhaps being held back by the government’s continued commitment to a policy of development-led growth. For example, it is far from clear how the Government’s policy position on aviation growth – which is fuelling airport expansion plans – will be consistent with its legal requirement to improve England’s ecosystem. Airport expansion can destroy or degrade habitats and the noise, light and air pollution can also put wildlife under pressure. 

Air quality targets

The Annual Mean Concentration Target (AMCT) 

The Annual Mean Concentration Target (AMCT) to reduce PM2.5 to 10 micrograms per cubic metre of air by 2040 is based on outdated air quality recommendations from the World Health Organisation (WHO), which has more recently (in September 2021) recommended reducing PM2.5 concentrations to 5 micrograms per cubic metre of air as soon as possible. The Government must show that it is serious about tackling polluted air in England and take a bolder approach, revising the AMCT to 5 micrograms per cubic metre of air by 2030.

Existing legal requirements under the National Emissions Ceiling Regulations (NECR) help to inform the need for policies to reduce emissions at source, but the Government’s new proposals omit any such target for PM2.5. In our response, we recommend that the air quality targets must include a PM2.5 emissions ceiling to ensure that emitters are required to reduce pollutants. In this regard, AEF is concerned to see that the consultation’s air quality evidence report omits reference to aircraft-generated particulate matter. Since the Government commits to adding PM2.5 monitors to the Automatic Urban and Rural Network and as there is a current lack of data about air pollution levels at airports, we feel strongly that additional monitors must be placed in residential areas located near to airports and under concentrated flightpaths taking account of the prevailing wind direction.  

We are also concerned about the lack of specific consideration for the effects of ultrafine particles (UFPs) from transportation and other sources, including aviation. Not fully understanding the health impacts of UFP is not a sufficient reason to avoid taking specific action to mitigate it, and measures taken now to mitigate or reduce could be cost-effective in terms of the health benefits gained. 

Population Exposure Reduction Target (PERT)

As with the AMCT, we are concerned that a 35% reduction in population exposure by 2040 is too little and too late. 

The UK Government has an unfortunate record of failing to meet legally binding air quality targets. To restore confidence, the Government must demonstrate that the AMCT as well as the PERT, will be met without campaigners having to resort to legal challenges. The Government must also clarify how airport (and other) planning decisions will help deliver legally binding air quality commitments in the context of its policy support for airport expansion (in the Airports National Policy Statement and Making Best Use).

Read our full response here: