Nature-based solutions: rhetoric or reality? - The potential contribution of nature-based solutions to net zero in the UK Contents

Chapter 3: Supporting nature-based solutions at scale in the UK

Turning pledges for nature into plans

89.The Government has targets for nature restoration and emissions reduction or sequestration that will rely on nature-based solutions. The targets are ambitious, but many previous promises to protect and restore nature have not been met. For example, a 2015 manifesto target to plant 11 million trees in England by 2020, matching the planting rate from 2010–5, was missed when planting rates fell.149 International targets have been missed: none of the 20 Aichi global targets for biodiversity restoration were met.150 Table 2 summarises Government pledges related to nature-based solutions.

Table 2: Government pledges related to nature-based solutions

Policy area



Tree planting

Plant 30,000ha per year in the UK by 2025; triple tree-planting rates in England (to 9,000ha) by the end of this Parliament.

13,000ha planted UK-wide in 2019 and 2020. The Net Zero Strategy pledges to consult on a long-term target.

Peatland restoration

Restore 280,000ha of English peatland by 2050, and at least 35,000ha by 2025.

Over 110,000ha of peatland has been restored in the UK since 1990.151 The Net Zero Strategy does not have separate targets for lowland and upland peat.

Agriculture, forestry and other land use sector emissions

Indicative pathway that emissions from the agriculture, forestry and other land use sector should fall by 27–43% by 2037 and 67–78% by 2050.152

Emissions have remained flat in this sector since 2007. The CCC noted that progress in this sector “repeatedly failed to meet the indicators” set out in its reports.153


75% of farmers to be “engaged in low-carbon practices” by 2030, rising to 85% by 2035.154 Fraction of farms in agri-environment schemes to increase to 70% by 2028. Up to 60% of England’s agricultural soil to be under sustainable management by 2030.

“Low carbon practices” are not defined. The Government defines ‘engagement’ as interacting with the Sustainable Farming Incentive, but the environmental benefits that will result remain unclear as a number of practices are covered by the Sustainable Farming Incentive. .155 Emissions have remained flat since 2007. 32% of farms are in agri-environment schemes today.

Protected areas

“Effectively protect” 30% of land and marine areas for nature by 2030 (30by30 pledge).

The Government considers 26% of land (in England) and 38% of marine areas to be protected.156

General environment

The 25 Year Environment Plan sets out goals related to the environment over the next 25 years.157

These targets include metrics for clean air, clean water, biodiversity, and climate change mitigation and adaptation.158


Halt biodiversity loss by 2030.159

The Environment Act 2021 provides for setting a specific target to halt species loss that is consistent with this pledge.160

Private finance for nature

Raise £500 million annually in private finance to support nature’s recovery by 2027 in England, rising to more than £1 billion by 2030.161

It is unclear how this will be defined and there are not figures for the amount of private finance currently being directed to nature recovery.

Global methane emissions

Reduce global methane emissions by 30% (on 2020 levels) by 2030.162

Global Methane Pledge (COP26). Global methane emissions rose almost 10% since 2000.163

Global forests and land use

Working collectively to halt and reverse forest loss and land degradation by 2030.164

Glasgow Leaders’ Declaration on Forests and Land Use (COP26). The 2014 New York Declaration on Forests also promised to halt deforestation by 2030 but missed its 2020 target to halve deforestation.165

90.The terms used in some pledges lack clarity. For instance, the absence of a definition for “effectively protect” undermines the pledge to effectively protect 30% of terrestrial and marine environments by 2030 (the 30-by-30 pledge). In chapter 1, we noted concern that bottom trawling is permitted in many Marine Protected Areas. While the Government considers 26% of land in England to be protected in some form, only 5% may be effectively protected under the definition of the International Union for the Conservation of Nature.166 The Government says it will support the 30-by-30 biodiversity target by bringing 50,000ha of protected sites into a “favourable condition”. It also says that there is “potential to create or restore 300,000ha of habitat by 2042, and bring over half of our [England’s] Sites of Special Scientific Interest into favourable condition by 2042.”167 But this is a small fraction of the 6.8Mha that has been designated as protected, much of which remains in an unfavourable condition or is not classified.168 The Environmental Audit Committee recommended that areas should be recorded as ‘conserved’ only if the measures to protect them are sufficient to restore them to good ecological status.169

91.The Committee on Climate Change has set out in its Land Use for a Net Zero UK strategy a set of policies that would be consistent with achieving net zero carbon emissions. Many of the Government’s pledges are aligned with the Committee on Climate Change’s recommendations, but some are not. For instance, the Committee on Climate Change calls for 67,000ha of peat restoration per annum by 2025, and for the full restoration of upland peat by 2045 (around 355,000ha in England) and for the re-wetting or sustainable management of 60% of lowland peat by 2050.170 But the Government has not matched the target for upland peat and it has no specific target for lowland peat. It will await the recommendations of the Lowland Agricultural Peat Taskforce.171 The Government is also committed to exploring a long-term tree planting target in the Net Zero Strategy, but it has not set one for 2050 as the Committee on Climate Change has done.172

92.The Government’s pledges for nature restoration are welcome and are largely consistent with the recommendations of the Committee on Climate Change (CCC). But some of its pledges are not aligned with those from the CCC. The pledges are undermined by a lack of clarity on the meaning of terms such as “protected areas” or “engagement with low-carbon farming practices.”

93.We recommend that the Government follows the recommendations from the Committee on Climate Change in setting targets for nature-based solutions. Where it does not do so, it should provide an evidence-based explanation as to why not, and how it can still reach net zero. It should define terms in its pledges where definitions are contested; this applies particularly to the term “protected”.

Public delivery bodies

94.Three bodies are mainly responsible for the delivery of the Government’s targets for nature and nature-based solutions on land in England: Natural England, the Environment Agency and the Forestry Commission.173 Marine nature-based solutions are in their early stages but are likely to fall under the joint remit of the Marine Management Organisation and Natural England.174

95.Natural England was established by the Natural Environment and Rural Communities Act 2006.175 Its purpose is “to help conserve, enhance and manage the natural environment for the benefit of present and future generations.”176 It aims to ensure that “nature-based solutions [contribute] fully to tackling the climate change challenge and wider environmental hazards”.177 It produces research into nature—for example, a recent report reviewed carbon storage and sequestration of habitats in England, which set out eight priorities for nature-based solutions in the UK.178 Its work in mapping and understanding nature will be supported by the £140 million in funding for the Natural Capital and Ecosystem Assessment project.179 It has an annual budget of £200 million and a staff of 2,000.180

96.The Environment Agency was established by the Environment Act 1995, and came into existence in 1996. It is the main organisation in charge of flood prevention and of setting regulations on air, land and water quality.181 It supports nature-based solutions that contribute to meeting these aims. For example, it designated 531 hectares of blanket bog, and restored a further 2,148 hectares, in 2019–20 to improve water quality and mitigate flood risk.182

97.The Forestry Commission is responsible for managing publicly owned forests and for regulating both public and private forestry in England.183 Its responsibilities include protecting and expanding woodlands, promoting their sustainable management and setting regulations for tree-planting.184

98.The Marine Management Organisation was created in 2009 by the Marine and Coastal Access Act.185 Its remit is to “protect and enhance our [the UK’s] precious marine environment, and support UK economic growth by enabling sustainable marine activities and development.”186 Alongside the Joint Nature Conservation Committee and Natural England, they have created and managed marine protected areas. They also aim to develop a marine planning system for the UK and set up a centre of excellence for marine information. As marine nature-based solutions remain largely at the research stage, the Marine Management Organisation’s activities in deploying them are limited mainly to establishing protected areas.187

99.Collaboration between the bodies charged with delivering nature-based solutions can help to achieve the Government’s targets.188 We heard about a £12.5 million project involving all the delivery bodies (and Kew Gardens) for nature-based solutions at the landscape level.189 The organisations will each take responsibility for the elements of the scheme that fall in their remit. Natural England will identify the sites and the appropriate interventions, the Environment Agency will ensure that the schemes contribute to co-benefits such as flood mitigation and it will work on funding mechanisms for co-benefits, while the Forestry Commission will set the regulations for carbon standards. Melissa Swartz, the catchment funding senior advisor at the Environment Agency, hoped that this scheme would “provide an example … of how public delivery bodies can work with each other … to enable the deployment of nature-based solutions at scale.”190

100.We heard concerns about the level of funding available to these organisations. Thomas Lancaster of the Royal Society for the Protection of Birds described a “hollowing out” of Natural England’s capacity “over the past 10 years.”191 The Environment Agency’s budget has been cut by around two-thirds since 2010, from £120 million to £40 million. Its chief executive said this affected its ability to monitor water pollution.192 Thomas Lancaster considered the agencies’ limited budgets to be inconsistent with the Government’s “ambitious agenda” and he thought that they would “need a lot more capacity than we currently have.”193 The Minister, Lord Goldsmith of Richmond Park, agreed that the Environment Agency and Natural England are being asked “to do more” and that they will need “more resources over time”.194

101.Collaboration between the delivery bodies is welcome and should be encouraged. But the Government’s targets for nature restoration demand a great deal of these bodies and their budgets are not adequate to meet the challenge.

102.We recommend that the budgets of the delivery bodies be increased to allow them to support the Government’s ambitious targets. The delivery bodies should be encouraged to collaborate so that the multiple benefits of nature-based solutions are realised. The Department for Environment, Food, and Rural Affairs should provide clarity over which responsibilities are delegated to each public delivery body for regulating and delivering nature-based solutions, especially for marine nature-based solutions.

Relevant policies

103.The Government has announced several policies to enable the roll out of nature-based solutions in the UK. The policies are at different stages of development and some details remain unclear. Table 3 sets out what is known so far.

Table 3: Government policies to support nature-based solutions


What does it do?

How much funding will it have?


Environmental Land Management schemes (ELMs) 195

These schemes will replace the agricultural subsidies of the EU’s Common Agricultural Policy (CAP) in England.196 They will move from the area-based payments used in the CAP, to “public money for public goods.”197 There will be three environmental land management schemes, which aim to incentivise practices at different scales. These schemes are set out below.

Current agricultural subsidies are £2.4bn per year in England, and the Department for Environment, Food and Rural Affairs has committed to the same overall level of spending in this Parliament as CAP is phased out and ELMs are phased in.198

The CAP will be phased out by 2028. ELMs are intended to replace the CAP as it is phased out.

Sustainable Farming Incentive (part of ELMs)

This will direct money towards environmentally sustainable on farm activities. The scheme will begin being rolled out in 2022 with an initial set of three standards.199 The Government aims for at least 70% of farmers, covering 70% of farmland, to take up Sustainable Farming Incentive agreements.200

One-third of overall funding for ELMs, subject to review.

It will be the main incentive for on-farm activities. There have been pilot schemes.201

Landscape Recovery Scheme (part of ELMs)202

This will support long-term, large-scale landscape level projects such as tree-planting and peatland restoration. Pilot scheme sites are set to be between 500–5,000ha and the pilot scheme is set to begin in 2022.203 The Government has said it will deliver at least 10 Landscape Recovery projects covering 20,000ha between now and 2024.204

One-third of overall funding for ELMs, subject to review.

This will replace the Nature for Climate Fund as the main funding for land sparing approaches.205

Local Nature Recovery scheme (part of ELMs) 206

This will support nature recovery projects which deliver local environmental priorities. The Government has listed activities that the scheme will support (see Box 1), but which activities will be supported in each location is likely to be identified by Local Nature Recovery Strategies when they are rolled out in 2022 (see below.) The Government intends to pilot the Local Nature Recovery Scheme in 2023 and roll it out nationwide in 2024.207

One-third of overall funding for ELMs, subject to review.

The Local Nature Recovery Scheme can be combined with the Sustainable Farming Incentive, providing different activities are paid for. The full details of payment rates and conditions that must be met have not yet been determined.208

Local Nature Recovery Strategies209

These will involve the comprehensive local mapping of 50 “strategy areas” across England to identify priorities for nature recovery and a map of habitats to conserve and restore. They are intended to bring together local expertise to identify and carry out local priorities for nature recovery.

Unclear; intended to be a mix of private and public including the Local Nature Recovery ELMS.

Will be introduced in England in April 2022 after recent piloting. Many of the details are yet to be confirmed.210

Nature for Climate Fund211

Provides public funding for tree planting and peatland restoration.

£750 million up to 2025.212

This will be the main source of funding for tree planting and for peatland restoration until 2025, when it will be replaced by ELMs.213

England Trees and Peat Action plan 2021–24214

This sets out policies for meeting the targets for peatland and trees. It aims to increase the use of timber in construction; to increase the supply of qualified foresters; to map England’s peatlands by 2024; to phase out sales of horticultural peat and restrict managed burning; and to publish a new Forestry Standard practice guide.


The restoration of peatland and trees will be funded by the Nature for Climate Fund.

Natural Environment Investment Readiness Fund215

This offers grants of £10,000–£100,000 to support environmental projects in England. These projects would support research that enables a market-based approach to restoring nature.

£10 million

It will be replaced by the £30 million Big Nature Impact Fund.216

Barriers to adoption of nature-based solutions

Transition to Environmental Land Management schemes

104.We heard that policy uncertainty is limiting the adoption of nature-based solutions. Farmers are caught between the phase-out of the EU’s Common Agricultural Policy (CAP) subsidies and the introduction of their replacements, which are Environment Land Management schemes (ELMs). The Environment Act 2021 provides that subsidies under ELMs will move from area-based payments to “public money for public goods.”217 ELMs will be more complicated than the pre-existing subsidies because they aim to achieve objectives for agriculture, nature, climate and biodiversity. But the details have not been set out. It is not clear how applications for ELMs will be assessed, or how the success of schemes will be measured. Richard Bramley, Chair of the National Farmers’ Union’s Environment Forum, who is enrolled in the Sustainable Farming Incentive pilot scheme, said “I am one of the farmers in question whom these policies are directed at … and do not have a clue how this is going to take shape”.218 The minister also acknowledged that “there is uncertainty on their (farmers’) part as regards what they need to do differently to ensure that the flow of income they depend on continues”.219

105.We heard from the Government that some uncertainty is inevitable due to the necessity of maintaining flexibility in the schemes as they are developed. Janet Hughes told us of the need to “strike a balance” between providing policy certainty and retaining “the ability to flex and adapt and learn as we go”. This “test-and-learn approach” means that “it [is] impossible for us to say … every single thing that we are going to do over the next seven years” without providing “false confidence.”220

106.Stakeholders are unclear about the duration of funding under ELMs. This is important because farmers “do not work, necessarily on Government five-year cycles.”221 It is also not yet known which activities will be supported.222 A landholder may want to adopt a nature-based solution on their land but be unwilling to invest in it because they are not sure that it will qualify for subsidies. For example, the Local Nature Recovery ELMs will support activities identified by Local Nature Recovery Strategies. But these activities that Local Nature Recovery Strategies will support cannot be identified before the intended introduction in April 2022.

Box 1: Local Nature Recovery Strategies

  • Local Nature Recovery Strategies will be introduced in England in April 2022. These strategies will map the opportunities to restore, conserve, or connect natural habitats in 50 ‘strategy areas’ covering all of England. Each strategy will include a list of priority opportunities for habitat improvement and restoration in the target area as well as a local habitat map of existing ecosystems.
  • The Department for Environment, Food and Rural Affairs will designate a “responsible authority” to guide the delivery of each strategy.223 Depending on the region, this may be a local authority, a public body like Natural England, or an organisation like the Wildlife Trusts or National Parks Authority.
  • Five short pilot projects of Local Nature Recovery Strategies took place from August 2020 to May 2021, and the outcomes of these short pilots will help in formulating policy, guidance, and regulations for local natural recovery strategies.224
  • These pilot schemes developed both a statement of biodiversity priorities and a local habitat map for each of the pilot areas. It is unclear what actions have followed the development of the strategies and whether the pilot projects were long enough for lessons to be learnt. The Government states that they are intended to be used by “a range of potential end users (including local authorities, Defra [The Department for Environment, Food and Rural Affairs], public bodies, landowners, Local Nature Partnerships, environmental organisations and developers).”
  • The pilots identified the importance of strong leadership, effective governance and collaboration between stakeholders. A lack of solid, accessible local data was a barrier, as were limited resources, with local areas not necessarily having the appropriate expertise and capacity to develop the strategies.
  • While the actions prioritised by the strategies will vary from place to place, the Government has stated that the Local Nature Recovery ELM will “particularly contribute to our targets for trees, peatland restoration, habitat creation and restoration and natural flood management.
  • The Government has outlined some activities that are expected to be supported by the schemes.225 These are intended to support: net zero; improved water and air quality; climate change adaptation; biodiversity; natural flood management; heritage; and coastal erosion mitigation. Some of these activities may also be supported by other schemes. It is not yet known what payment rates will be. The Government said it will publish additional details later in 2022.

Source: Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery Strategy pilots: lessons learned’ (12 July 2021): [accessed 10 December 2021]

107.There are also uncertainties about how schemes will interact with each other.226 For example, Professor Reed told us that land managers are unclear whether payments under ELMs can be combined with private finance under carbon codes.227

108.The Government wants farmers to be able to access private finance alongside government schemes and ensure that farmers are better off when they seek private financing, but consultations are ongoing as to how this can work .228 Janet Hughes of The Department for Environment, Food and Rural Affairs explained that the Government does “not know yet” whether there will be overlap between public and private schemes as “these markets are nascent and the rules are not yet well established.”229 Within ELMs, the Government has said that farmers will be able to apply for both the Sustainable Farming Incentive and the Local Nature Recovery scheme, providing they do not pay for the same activity.

109.Thomas Lancaster summarised the consequences of this lack of clarity:

“Lots of farmers and land managers, when they are looking at whether they should engage with the nature-based solutions agenda and the broader sustainable land management agenda, can be forgiven for hesitating and thinking, ‘Well, should I go now, or should I wait to understand what the best returns are going to be for me? If I go into this scheme that’s currently available, will I get paid less than if I were to wait for a scheme that might be available in two or three years’ time.’”230

110.The transition from the Common Agricultural Policy to Environmental Land Management schemes will require long-term changes to land use, but funding is not yet guaranteed in the long term.

111.We recommend that the Department for Environment, Food and Rural Affairs provides urgent clarity about the nature of Environmental Land Management schemes and which activities they will subsidise. Funding should be assured in return for a long-term commitment to good practice. The new schemes that are introduced should be based on proper and transparent evidence. They must have defined metrics to evaluate success or failure so that they can be adapted to evolving evidence. It must be clear how these schemes will interact with wider agricultural and environmental policies.

112.We heard that some stakeholders do not support the proposed shift from productive farming to the provision, under the Environment Land Management Schemes, of “public money for public goods”.231 Professor Rosemary Hails, the Director of Science and Nature at the National Trust, said: “some farmers very much want to continue doing what they have always done … an element of cultural change is needed.”232 Harry Studholme described a cultural barrier to turning land over to tree-planting with “people who have spent their lives farming finding it difficult” to “make sense of an increasingly forested environment.”233 We were told that farmers are “embattled” rather than “enthuse[d]” and that they feel blamed for agricultural emissions from livestock.234 Both the Country Land and Business Association and the National Farmers’ Union warned that the absence of effective communications about the transition could lead to mistrust, misinformation and confusion.235 The Public Accounts Committee similarly found that the “lack of information” from DEFRA is causing “anxiety in the sector” and that the “engagement” had “a long way to go”.236

113.Land-sharing practices like agroforestry or paludiculture (farming on wetlands) can be integrated with productive farming. Farmers are likely to be less reluctant to move to practices that allow them to continue farming, rather than a large-scale move away from food production. The National Farmers Union told us in its written evidence that “our vision is based on land sharing, not land sparing.”237 However, as set out above, the carbon accountancy of land-sharing practices is less certain, the carbon savings are smaller and many farmers have no experience of using these methods.

114.The transition to Environmental Land Management schemes demands a lot from land managers and farmers. Some of them feel that they do not have sufficient support. Poor communication and a failure to convince land-managers of the benefits of the change will lead to a transition that fails. Maintaining flexibility in Environmental Land Management schemes to permit land sharing approaches could help to address the lack of engagement and reluctance from land managers.

115.We recommend that the Government improves communication with land managers. Land sparing approaches will have to play a significant role in reaching net zero targets, but land-sharing approaches should be included in Environmental Land Management schemes where possible, and where evidence suggests they deliver carbon benefits. This will make the transition to providing “public money for public goods” easier and more acceptable for land managers.

Knowledge and skills

116.We heard that there is a knowledge and skills gap in planning and carrying out nature-based solutions. Many farmers are unable to assess which nature-based solution is most appropriate for their land. Richard Bramley described “fundamental challenges when it comes to measuring carbon” and greenhouse gas accountancy on existing holdings.238 Harry Greenfield, the Senior Land Policy Adviser of the Country Land and Business Association, said schemes should be “frontload[ed] … with advice and training” so that land managers can establish “the baseline environmental value of their land and what they could deliver.”239 With no baseline, land managers cannot predict and measure the impact of a shift to low-carbon practices.

117.Skills gaps exist in other sectors. The support of local authorities for the Local Nature Recovery Strategies will be essential, but the Association of Local Government Ecologists noted that fewer than a third of local authorities have ecological expertise.240 The Institute of Chartered Foresters said that a skills gap in tree-planting could undermine climate targets, and we heard from Professor Henderson that forestry skills “have deteriorated in the country over recent decades”.241 Richard Lindsay told us that, for the heavily emitting lowland peats, “the hoped-for strategy/solution” is “this new concept of wetland farming” but the skills required for that do not exist.242 Professor Stead, Chief Scientific Adviser, Marine Management Organisation, told us of marine nature-based solutions for which “the training and capacity-building is not at a mature stage.”243

118.We heard that land managers will require additional training. Managing land for the climate and nature is different from maximising yield.244 Advice to engage with the schemes will be particularly important given the lack of clarity around them and their complexity, which we set out above. In the past, Natural England helped farmers to engage with agri-environment schemes, but Thomas Lancaster told us that “if you speak to most farmers, they will say they have not seen anyone from Natural England for a long time.”245 We were told of an erosion of trust between farmers and government agencies.246 The Government has indicated that communications will improve by 2024, from when “it will no longer be necessary for people to navigate multiple schemes and forms … both the Sustainable Farming Incentive and the Local Nature Recovery will be accessible through a simple digital service which shows each farmer all options available to them.”247

119.Professor Chris Collins said that “the key thing is education for the farmers. We used to have a fantastic advisory service … A lot of farmers cannot afford consultants, and if we are really going to change behaviour … We need to think about a national advisory service.”248 Harry Greenfield of the Country Land and Business Association said “Each farm should have a land management plan that sets out what they are currently doing on their land and what they would like to do over the next years of the agreement they might be in.”249 The Government agreed that land management plans were “a good way to assess the potential to deliver environmental benefits on [land manager’s] land … ” and it has committed to explore how they might be used.250 The Government is currently providing £10.7m of grants to third-party advisors to help farmers understand the agricultural transition through the Future Farming Resilience Fund.251

120.Lord Goldsmith of Richmond Park acknowledged the scale of the skills challenge, saying that “we are at the beginning of one of the greatest transitions this country has ever been through … on a par with the Industrial Revolution.”252 However, he said “it would be wrong to pretend, at this stage, that the skills that will be needed in the medium and long term have been fully mapped out and identified, and that our workforce of the future, based on where we are today, will be ready for that challenge.”253 He told us that the Department for Environment, Food and Rural Affairs are currently talking to the Department for Education to identify and address these skills gaps but he acknowledged that the urgency of the agricultural transition leaves little time: “to hit the 2030 targets on biodiversity, we cannot wait until 2028 to have people doing that work.”254

121.We welcome that the Government recognises the existence of gaps in the skills and knowledge needed to carry out nature restoration, but we are concerned that plans to address the gaps lack urgency.

122.We recommend that the Government establishes ambitious skills and training programmes for land managers, authorities developing Local Nature Recovery Strategies and public delivery bodies. Training in surveying, monitoring and verifying, carbon accountancy, forestry, ecology, and planning and carrying out nature-based solutions needs to be expanded urgently. The Department for Education and the Department for Business Energy and Industrial Strategy must allocate some of their funding to this effort to make schemes accessible to land managers and provide sufficient skilled personnel to meet targets.

123.Land managers cannot assess the best actions to take without assistance. While the Committee welcomes the Government’s commitment to making its schemes easier to access, and providing support to third-party advisors through the Future Farming Resilience Fund, it is difficult to see how widespread engagement with schemes will be achieved without a significant expansion in advisory services and support.

124.We recommend that the Government provides additional support as a matter of urgency for land managers, in the form of a dedicated advisory service, to help them engage with Environmental Land Management Schemes. The advisory service should be delivered in collaboration with public delivery bodies and should help land managers through the application process. It should help farms to identify the most appropriate actions to take, the support they need and can expect, and the likely environmental impact of their actions.


125.Tenancy arrangements can be a barrier to tenant farmers implementing nature-based solutions. Tenant farmers work around 30% of land in the UK.255 But their tenancy contracts can contain clauses that require them to manage land only for agricultural purposes.256 There is also little motivation for tenants to invest in nature-based solutions if the long-term benefits will accrue to the landowner rather than to them. We heard that this can incentivise suboptimal land management, because the focus is on generating profit from the land in the short term.257 Furthermore, short term tenancy contracts mean that tenant farmers do not have sufficient time to oversee changes in land use. Lord Goldsmith of Richmond Park acknowledged that the Government would “not be able to meet our targets” without the full involvement of tenant farmers, but that he would “not pretend that we [the Government] have resolved those issues.”258

126.Professor Mark Reed, the Professor in Rural Entrepreneurship, at Scotland’s Rural College, told us of a possible solution. There are “contractual arrangements” where “the units are owned by the landowner” but where the “benefits” are shared between landowners and tenants.259

127.Tenancy contracts impede the implementation of nature-based solutions. More flexibility in these contracts is needed for the Government’s schemes to be a success.

128.We recommend that the Government urgently addresses the barriers tenant farmers face to engage with the Environmental Land Management Schemes. This could include mechanisms for landlords and tenants to negotiate arrangements that allow them to share the costs and benefits of improvements.

Supply chains

129.We heard concerns that an insufficient supply of the resources needed for nature-based solutions could slow their adoption. From Dr Waring, we heard concern about ensuring sufficient “nurseries and … seed stock to support the scale of expansion”.260 Dr Lisa Norton told us that for “productive, species-rich grassland”, it is “difficult to get hold of suitable seed.”261 Relying on overseas imports of trees risks importing pathogens. Professor David Coomes said that “there are horrifying statistics about how many new pests and diseases arrive each day” and he urged the Government to counter these risks with phytosanitary measures.262 We have already emphasised the importance of resilience, and imported diseases threaten the long-term future of many trees.

130.We recommend that the Department for Environment, Food and Rural Affairs supports the domestic industry for seeds and saplings and only imports bio-secure seeds and saplings where necessary, and with stringent phytosanitary safeguards.

Private finance for nature-based solutions

Woodland Carbon Code and Peatland Code

131.In England, the Government wants to see £500 million of private finance be directed towards nature restoration annually by 2027, rising to £1 billion by 2030.263 The Woodland Carbon Code and the Peatland Code (hereafter—the codes) are the main Government-backed schemes to attract this finance. Further carbon codes for different ecosystems, including saltmarsh and soil, are being developed or explored.264

132.The codes set out standards and requirements for privately financed, voluntary carbon sequestration projects in woodlands and peatlands.265 They provide a scientific basis for predicting and for monitoring the carbon sequestration from interventions, and for the independent validation of projects.266 They allow private investors to pay a landholder to sequester carbon on their land by planting trees or by restoring peatland. They do not issue emissions certificates that can be traded on global carbon markets or in the UK Emissions Trading System.267 Instead, they issue carbon units that can be counted against greenhouse gas emissions under mandatory greenhouse gas reporting requirements in the UK.268

133.The Government supports the Woodland Carbon Code with public money through the Woodland Carbon Guarantee. In this scheme, the Government commits to purchasing Woodland Carbon Units at a fixed price as they mature, over 35 years. The overall sum for the Guarantee is £50 million and land managers bid in competitive auctions for the contracts, which will occur every six months until this funding has been allocated, over a period of 4–5 years.269 Once this funding has been allocated, it is unclear whether the scheme will be continued. Four such auctions have taken place so far, with a total of 2,650 hectares of woodland supported by successful bids.270

134.Safeguards are in place to ensure that the codes will deliver as promised. The codes issue two types of credit. Pending Issuance Units (PIUs) are promises to sequester a tonne of CO2-equivalent, while Woodland or Peatland Carbon Units represent a tonne that has actually been sequestered.271 Projects are checked at five-year intervals to assess their storage of carbon. Only if the PIUs are verified can they be converted into carbon units, which can be counted in greenhouse gas reporting requirements. There are additional safeguards to ensure that the carbon is stored permanently and that additions to the stored carbon are occurring.272

135.It is not clear what proportion of PIUs will be converted into verified units. So far, the numbers are small, but this is to be expected, given how recently the schemes were established. Since 2010, over 5.8 million woodland PIUs have been issued and 3.1 million sold, for prices between £7–20, but only 800 had been verified as of September 2021. None of the ~150,000 PIUs issued under the peatland code have been converted to realised credits, since it was developed later than the Woodland Code.273 Dr Snowdon, the Head of Economics and of the Woodland Carbon Code at Scottish Forestry, and Dr Hermans, the Peatland Code Coordinator at the IUCN UK Peatland Programme, were confident that most projects would succeed.274 However, James Mansfield of Finance Earth raised a concern with the model of “forward sell[ing]” carbon through PIUs. If landholders spend the up-front capital earned from selling the PIUs the “projects effectively have no future income to support their operating costs.”275 This could result in schemes reverting to their previous state through lack of maintenance. He noted that management of finances could prevent this issue but “because these are voluntary codes, there are no specific rules or even guidance on what that best practice looks like.”276

136.About 44,700ha of woodland have been registered under the Woodland Carbon Code since 2011. Around 17,000ha of additional projects were submitted in the financial year 2020–21.277 Projects currently registered under the scheme are projected to sequester 15.4Mt CO2e over their lifetime of up to 100 years.278 Under the peatland code, 5,237ha of peatland has been registered, with a Government target of restoring 35,000ha by 2025.279 We heard from James Mansfield that the carbon units covered by the codes are “seeing massive demand, which is outstripping supply.”280 Improving the engagement of land managers with high quality, scientifically based schemes could correct this shortage of supply.

Co-benefits and the codes

137.We were told that a major gap in the codes is the absence of a mechanism to value co-benefits. David Young identified this as “the very precise reason” that “we see a supply constraint.”281 Investors may informally appreciate co-benefits: Dr Snowdon told us that investors considered Woodland Carbon Credits to be “charismatic carbon.”282 But credits from projects with more co-benefits are of no more value to the investor or the landholder. Annette Burden, wetland biogeochemist, UK Centre for Ecology and Hydrology, who is developing a saltmarsh carbon code, told us that for some ecosystems, projects will not be viable if co-benefits are not taken into account.283

138.Various witnesses described the value of enabling “stacked” and “blended” finance to support nature-based solutions. Stacked finance would involve multiple buyers purchasing ecosystem services from the same project, while blended finance is a combination of public and private finance. Annette Burden explained that saltmarsh restoration projects are mostly funded for flood defence, but this may provide only “80% funding … it might then be through carbon financing that we could finance the remaining 20%.”284 This is an example of stacked finance, where one buyer might pay for the flood defences while others pay for the carbon sequestration. Annette Burden noted that this could be “complex, especially if you had different customers for the different services and you had to get them all to agree to commit to funding at the same time”, but “not impossible.”285 Dr Snowdon, of the Woodland Carbon Code, spoke of a “discussion … with DEFRA [the Department for Environment, Food and Rural Affairs]” about developing “biodiversity credits” which would be “stack[ed]” on top of carbon credits.286 Many of the projects supported by the Natural Environment Investment Readiness Fund are hoping to establish new markets for payments for ecosystem services which could be combined with financing via carbon credits.287

139.We heard from Lord Goldsmith of Richmond Park that “if you judge a project purely on the basis of its carbon sequestration value, you can end up with perverse policies”. He said that the Government would consider co-benefits in determining which projects it supported, but that “recognition of those benefits by the private sector … is harder.”288

140.Monetising co-benefits would make nature-based solutions projects more financially attractive for landholders and investors. Some ecosystem restoration projects will not be viable unless their wider benefits for the environment and for society, including for biodiversity and flood risk mitigation, are valued. Financing projects based on multiple benefits will make more projects viable, but requires central coordination to match buyers and sellers.

141.We recommend, although it will be complex, that the co-benefits of projects under the Woodland Carbon Code and the Peatland Code should be quantified, and that payments for other ecosystem services should be included within current and future carbon codes. This should be facilitated by the Government bodies that manage each carbon code.

Practices funded by the codes

142.Another potential issue is that a variety of beneficial practices, beyond large scale tree planting or peatland restoration, are not incentivised under the codes. Professor Evans identified an agricultural nature-based solution of draining agricultural peatlands to a lesser depth to reduce emissions.289 Harry Studholme told us that additional carbon would be sequestered if trees were grown for longer before harvesting. But neither of these improved management practices would fall within the additionality requirements of the codes, despite reducing emissions and benefiting nature when used appropriately.290

143.Dr Hermans was concerned that standards for net zero might fail to recognise peatland restoration and that they might reduce demand for the Peatland Code. This is because restoring peatland does not, at least in the short-term, sequester CO2—it prevents it being emitted. This means the Peatland Code is “selling emissions reductions” rather than active sequestration.291 Helen Avery, Head of Nature Programmes, Green Finance Institute, told us that this lack of clarity on whether peatland credits will be regarded as offsets under net zero declarations “could discourage investors.”292

144.There is a lack of agreed standards for projects and ecosystems other than large-scale tree-planting and peatland restoration. Some beneficial land use practices, such as improved management of working forests or agricultural peatlands, that sequester carbon or prevent it from being emitted are excluded from the Woodland Carbon Code and the Peatland Code.

145.We recommend that the Woodland Carbon Code, the Peatland Code, and greenhouse gas regulations, incentivise means of actively restoring ecosystems. These practices would prevent additional emissions from ecosystems that would otherwise degrade, even if they did not sequester carbon.

Net zero and private finance

146.Net zero ambitions should provide an opportunity for directing private finance towards restoring UK nature, as companies buy offsets to reach net zero emissions. We heard that “since the net zero targets came in, there has been a huge surge in interest” for the carbon credits offered by the codes.293 A recent study by S&P found that the price of nature-based offsets increased threefold between June 2021 and January 2022. 294 A higher carbon price may incentivise more landowners and managers to turn over their land to nature-based solutions, but pressure on suppliers to generate carbon credits quickly may compromise the quality of the offsets.

147.The role of mandatory greenhouse gas reporting, in which carbon code units can be used in calculations and claims of overall emissions, is unclear.295 There are no regulations on what is required for companies to claim that they have achieved net zero emissions and the high standards set by the carbon codes do not apply to all carbon credits.296 Companies can make net zero claims by buying cheap, low-quality offsets internationally, which may have unclear benefits for nature.297 Recent claims by companies of being “carbon negative” may rely on offsets as cheap as $3/tonne.298 This significantly undercuts existing, well regulated, carbon pricing mechanisms, which are intended to reflect the true cost of avoiding carbon emissions. For example, under the UK’s emissions trading scheme, there is a carbon price of around £50 per tonne of CO2 emitted.299 We heard from James Mansfield that regulations on net zero emissions were “part of the market infrastructure that … does not really exist … being much clearer about what the net zero pathway looks like and where legitimate offsetting sits … will help to accelerate the growth” of demand for the markets.300

148. Some companies have signed up to the definition of net zero in the Science-based Targets Initiative.301 This scheme allows companies to submit their net zero plans and targets to an expert team for validation. This entails identifying the emissions for which the company is responsible and then setting out a clear and appropriate role for offsetting alongside emissions cuts, and near-term actions and targets. For most corporations, this entails rapidly cutting emissions now, halving emissions by 2030, reducing total emissions by 90–95%, offsetting only the remaining 5–10%, and not claiming net zero until long-term targets are reached.302 We heard from Lord Goldsmith of Richmond Park that the Government supports the Science-based Targets Initiative, and that it should be expanded to include impacts on nature. But it remains a voluntary standard for corporate net zero plans.303 The incentive for companies to invest in nature-based solutions so they can reach a net zero target is weaker than it could be.

149.Offsets cannot be a substitute for reducing emissions. But the drive towards net zero emissions is an opportunity to direct significant private finance to nature recovery in the UK in the form of offsets. The role of carbon credits in net zero declarations remains unclear. Schemes like the Science-based Targets Initiative provide good standards but remain voluntary.

150.We recommend that the Department for Business, Energy and Industrial Strategy must provide clarity about what companies must do to claim net zero emissions. Regulations should include a limited, defined role for high-quality offsets, such as the 10% limit in the Science Based Targets Initiative, alongside incentives to ensure emissions are reduced to the full extent possible at the same time.

The need for well-regulated environmental markets

151.We heard concerns about using a market-based approach to fund nature-based solutions. For example, David Young told us that in environmental markets around the world “brokers and intermediaries … quite often consume all the value that is created.”304 In the push to create markets for ecosystem services, mistakes made in previous schemes risk being repeated. David Young of Wheatley Young Partners urged the Government to provide “co-ordinated … regulatory frameworks”, following the guidance of the Financing UK Nature Recovery project.305 He told us:

“We have seen the consequences of a more laissez faire market in the voluntary carbon sector. Mark Carney has now had to come in, 20 years on, and try to put a bit more rigour and discipline into those markets. We are at the beginning of the markets for nature, and it is really important that we put these frameworks in from the outset, so that in 20 years’ time we do not have to find another Mark Carney to fix the problem.”306

152.The Article 6 rules, agreed at COP26, determine how carbon markets and the associated carbon accountancy should operate internationally. They exclude credits associated with an earlier UN scheme, REDD+, which paid for “avoided deforestation”, where the benefits were thought to have been overstated.307 In this case, a market developed to facilitate the trade of these credits, but poor regulation led to little benefit to the environment.

153.We heard from Professor Henderson, that for habitats such as soil, saltmarsh, or seagrass: “the metrics to measure and understand them are insufficiently mature that you would want to count them at this stage in an offset market or in an accounting scheme”.308 Research and development to improve the evidence base to develop sufficient regulatory standards is part of the purpose of the Natural Environment Investment Readiness Fund.

154.There are unofficial soil carbon markets that demonstrate the importance of Government regulation. The Woodland Carbon Code and Peatland Code have numerous safeguards to ensure that the schemes are robust, but nascent soil carbon markets lack these safeguards. Professor Hails told us that an official soil carbon code is “badly needed” as “farmers think they are dealing with people who are certified” but who are, in fact, operating privately without full certification.309 Richard Bramley told us that farmers risk being “hoodwinked” in such carbon markets.310 However, as noted above a soil carbon code will be difficult to develop because of the limited scientific evidence and the range of practices that it will have to cover.311

Other concerns

155.We heard concerns that the complexity of the marketplace underpinning the codes could limit the scale of investment. Buying a Woodland or Peatland Carbon Unit requires the buyer, or an appointed carbon broker, to negotiate with a supplier to support a pre-designed project.312 David Young suggested that the ability of code operators to aggregate multiple projects could increase investment.313 But Annette Burden was unclear how the current marketplace would coordinate payments from multiple buyers.314

156.Witnesses told us that while the private sector can play a role in supporting nature-based solutions, Government support will still be required. On peatlands we heard from Dr Hermans that, “restoration is really pretty expensive. Doing that on just private investments, carbon credits, at the current prices is really difficult, so we still need a blended approach of public and private funding.”315 James Mansfield emphasised the role of price floor mechanisms that should be provided by the Government. These would guarantee a minimum price of a carbon unit for a landholder, providing “confidence and certainty”. He suggested that the Woodland Carbon Guarantee could act as a model for this approach.316 Lord Goldsmith of Richmond Park acknowledged that it will be “incredibly difficult to turn nature into a market.”317

157.The market can incentivise investment in nature-based solutions. But the rush to develop new markets, with bottom-up initiatives, risks creating inconsistently regulated offsetting markets that do not deliver benefits to nature. Existing carbon markets are also complex.

158.We recommend that the Government provides clear regulatory standards for emerging carbon markets to ensure that any offsets that are claimed are genuine. The Government should make carbon codes easier to use by acting as, or sponsoring, a central broker. Buyers and sellers should be able to aggregate multiple projects and combine public and private funding.


An overall land-use strategy?

159.As we have argued, the agricultural transition and the push to achieve net zero emissions will place multiple demands on UK land. Land will have to be used for, amongst other things, food production, sequestering greenhouse gases, crops for bioenergy and, havens for biodiversity, as well as demands from entirely different uses such as house building. The Country and Land Business Association describes this as a “radical shift in the land use sector”, while the minister compared it to the industrial revolution.318 In chapter 1, we referenced the land use pathway described by the Committee on Climate Change, which requires up to 22% of UK agricultural land to be taken out of production.319 In order to reconcile the competing demands on UK land, the Committee on Climate Change has declared that food waste and beef and dairy consumption must be reduced, while yields on remaining agricultural land must be increased.320 We have also heard concerns about the offshoring of emissions if environmentally damaging activities are displaced elsewhere in the world when they cease in the UK.

160.Concerns have been raised about the structure and the transparency of land ownership in the UK. This report has already discussed the issues facing tenant farmers, who rent from landowners, in deploying nature-based solutions on their land. Determining the ownership of land in the UK is hampered by a lack of transparency, According to the Land Registry, “anyone buying or selling land or property, or taking out a mortgage must apply to us [the land registry] to register”.321 The Land Registry has evidence of ownership for 87% of land mass in England and Wales. But one estimate found that 17% of land in England is not detailed in the Land Registry.322 This may make it difficult for the Government to identify which stakeholders it needs to engage with. However, much of the land relevant to nature-based solutions is owned by a small number of people. For example, it has been estimated that 124 individuals and organisations own around 60% of UK peatlands.323 The decisions of a small number of individuals could have significant implications for nature-based solutions in the UK. The Government also has direct control of some UK land through bodies like the Ministry of Defence, which owns 1% of UK land.324 While, in the marine context, the Crown Estate, which was established in its modern form by Act of Parliament,325 controls the UK’s territorial seabed within 12 miles of the shore.

161.The Government is aware of the challenges posed by the need to balance competing demands for land use. Professor Henderson noted that “there is limited land and we are trying to get a lot of environmental benefits from it”, while Lord Goldsmith of Richmond Park acknowledged that for “lots of land … there will be competition for use”.326 Reconciling food production and the protection of nature was described as a “central challenge for DEFRA [the Department for Environment, Food and Rural Affairs]”.327 Lord Goldsmith of Richmond Park noted that “offshoring of our food production is not a good idea” and described the problem of changing diets as “the hardest nut to crack” politically.328 Both the Department for Environment, Food and Rural Affairs in its written evidence and Lord Goldsmith in oral evidence set out the importance of a “strategic approach to land management”.329 Lord Goldsmith agreed that there is a “need for greater integration of the needs of the natural environment and the needs of humans”. This requires a closer collaboration between the Department for Environment Food and Rural Affairs and Department for Levelling up, Housing and Communities.330 But Lord Goldsmith was “not convinced that we [the UK] need a single land strategy.”331

162.The trade-offs in land use must be addressed; and it is difficult to see how this can be done without an overall strategy. Harry Greenfield told us that managing these trade-offs would require thinking “carefully about what each piece of land is used for and how it is managed. For us, that means that policy cannot be delivered in silos. You cannot have targets for development and housebuilding, for example, on one side, then climate and nature, and then food production. They need to be considered holistically, which does not always happen.”332 In their recent report, the Public Accounts Committee noted that “the Department [for Environment Food and Rural Affairs] has given no detail about how either the necessary productivity increases or environmental benefits will be brought about” and that it had not “explained how the Scheme’s [ELMs] changes in land use will not simply result in more food being imported.”333

163.In 2022, a House of Lords special inquiry committee will be established to consider land use in England.334 Its remit will enable it to investigate current and future demands on land use, their impact on climate change and the decision-making processes concerning land use.335

164.Reaching the net zero emissions target will require managing trade-offs in land use. There is no guarantee that a voluntary or market-driven approach will create local schemes that will achieve the national climate and nature targets.

165.We recommend that the Government develops an overall land use strategy. This should outline how nature-based solutions will contribute to net zero emissions, how they will be integrated with other policies and how trade-offs in land use will be managed. The Government needs to describe how the UK’s land can deliver the multiple services demanded of it without offshoring emissions. The Government should work with large landowners, including land and marine managers such as the Ministry of Defence and the Crown Estate, to achieve its objectives.

Risk of failed transition

166.The Government’s plans are ambitious and have much potential, but there is a clear and present danger that they will not be achieved. There are multiple risks of failure, including a lack of certainty about the science of carbon sequestration in nature-based solutions, a lack of skills and engagement, and a lack of policy coordination, which require urgent actions to address. Failure to deliver risks the livelihoods of farmers, damaging the agricultural sector, undermining the net zero agenda, and risks undermining the UK’s biodiversity-recovery.

149 An October 2019 written response from the Government did not specify how many trees had been planted in the period from 2015 but said that “15 million trees have been planted since 2010”, which would appear to leave a substantial shortfall. Hectare data from Forest Research statistics would support this. House of Commons Library, Tree Planting in the UK, Briefing Paper 9084, June 2021. Written Answer UIN 7178, Session 2019. Forest research, ‘ New planting in England, 1971–2021’:–2021revised.xlsx [accessed 13 January 2022]. The Conservative Party Manifesto 2015, p 54: [accessed 13 January 2022]

150 In the UK, five of the targets—set in 2010—were on track to be achieved by 2020, but 14 were not. Joint Nature Conservation Committee (JNCC), Sixth National Report to the United Nations Convention on Biological Diversity: United Kingdom of Great Britain and Northern Ireland (March 2019):; and JNCC, Sixth National Report to the United Nations Convention on Biological Diversity: United Kingdom of Great Britain and Northern Ireland, Overview of the UK Assessments of Progress for the Aichi Targets (March 2019): [accessed 12 January 2022]

151 IUCN Peatland Programme, UK Peatland Strategy 2018–2040, p 38:–015-En.pdf [accessed 7 January 2022]

152 The Net Zero Strategy does not set an emissions target for this sector but it does include an “indicative pathway”, illustrating the scale of the contribution expected from the sector. It outlines policies that are intended to contribute to meeting the target but does not set out how these add up to the proposed fall in emissions. DEFRA officials told us they will announce a target shortly and it will likely follow this indicative pathway. 122 (Janet Hughes). The Committee on Climate Change maintains a series of key progress indicators for the sector and outlines gaps between targets and policies in its reports. Committee on Climate Change, Progress in reducing emissions, 2021 Report to Parliament (June 2021) Table 3.4, p 119: [accessed 7 January 2022]

153 Committee on Climate Change, Progress in reducing emissions, 2021 Report to Parliament (June 2021) p 93: [accessed 7 January 2022]

154 HM Government, Net Zero Strategy: Build Back Greener (October 2021) p 167: [accessed 7 January 2022]

155 In the Net Zero strategy, the Government acknowledges that the definition of this pledge is not clear commits to “continue to improve this metric in future years” due to “key limitations in the current approach.” HM Government, Net Zero Strategy: Build Back Greener (October 2021) p 171: [accessed 7 January 2022]

156 Prime Minister’s Office, ‘PM commits to protect 30% of UK land in boost for biodiversity’ (28 September 2020):; Marine Conservation Society, ‘ Protected seas around the UK’: [accessed 7 January 2022]

157 Department for Environment, Food and Rural Affairs, ‘At a glance: summary of targets in our 25 year environment plan’ (22 October 2021): [accessed 7 January 2022]

158 The 25 Year Environment Plan was adopted based on recommendations from the Natural Capital Committee. This advice included setting specific, legally binding targets for air and water quality, biodiversity, resource efficiency and waste. The Environment Act 2021 gives the minister power to set these targets by regulation and establishes the new Office for Environmental Protection for monitoring progress. Natural Capital Committee, End of Term Report (November 2020) p 3: [accessed 7 January 2022]

159 Leaders pledge for nature: [accessed 7 January 2022]

160 Environment Act 2021, section 3

161 HM Treasury, Autumn Budget and Spending Review 2021, HC 822 (October 2021) p 72: [accessed 7 January 2022]

162 UN Climate Change Conference UK 2021, ‘World leaders kick start accelerated climate action at COP26’ (2 November 2021): [accessed 7 January 2022]

163 Quirin Schiermeier, ‘Global methane levels soar to record high’, Nature (14 July 2020):–020-02116-8 [accessed 7 January 2022]

164 UN Climate Change Conference UK 2021, ‘Glasgow leaders’ declaration on forests and land use’ (2 November 2021): [accessed 7 January 2022]

165 New York Declaration on Forests, Protecting and Restoring Forests A Story of Large Commitments yet Limited Progress—5-year assessment report (September 2019): [accessed 7 January 2022]

166 Prime Minister’s Office, ‘PM commits to protect 30% of UK land in boost for biodiversity’ (28 September 2020): [accessed 7 January 2022]. The Government aggregates a number of different designations for areas into “protected areas” for the 30by30 pledge, including Areas of Outstanding Natural Beauty, National Scenic Areas, National Parks, National Nature Reserves, Sites of Special Scientific Interest, Special Protection Areas and Special Areas of Conservation. These will all have different definitions and applicable standards for protection. Starnes et al., ‘The extent and effectiveness of protected areas in the UK’, Global Ecology and Conservation, vol. 30 (October 2021): [accessed 7 January 2022]

167 Department for Environment, Food and Rural Affairs, Environmental land management schemes: outcomes, policy paper, (6 January 2022), [accessed 11 January 2022]

168 Joint Nature Conservation Committee (JNCC), ‘UK Biodiversity Indicators (UKBI) C1. Protected areas’ (October 2021): [accessed 10 January 2022]

169 Environmental Audit Committee, Biodiversity in the UK: bloom or bust? (First Report, Session 2021–22, HC 136)

170 Committee on Climate Change, Progress in reducing emissions, 2021 Report to Parliament (June 2021) p 120:; and Committee on Climate Change, The Sixth Carbon Budget, The UK’s path to Net Zero (9 December 2020) p 72, 170: [accessed 13 January 2022]

171 HM Government, Net Zero Strategy: Build Back Greener (October 2021) p 178: [accessed 13 January 2022]

172 HM Government, Net Zero Strategy: Build Back Greener (October 2021) pp 178–9: [accessed 13 January 2022]

173 These bodies have jurisdiction over England; the situation in the devolved administrations differs. Natural Resources Wales consolidates the responsibilities of the three delivery bodies listed for England into one body. Scotland has NatureScot as its equivalent of Natural England, the Environment Agency Scotland, and Scottish Forestry as its equivalent of the Forestry Commission, as well as Forestry and Land Scotland which manages the national forests in Scotland.

174 Natural England’s research projects have included mapping potential nature-based solutions in marine and coastal territories, but the Marine Management Organisation has a remit which includes protecting the marine environment and has written about the importance of nature-based solutions. Marine Management Organisation, ‘MMO and COP26’ (2 November 2021): [accessed 10 January 2022]. For this reason, it is unclear how responsibility for marine nature-based solutions will be divided between these two delivery bodies.

176 Natural England, ‘About us’: [accessed 10 January 2022]

177 Natural England, ‘About us’: [accessed 10 January 2022]

178 The eight priorities were: “Protect and restore peatlands; create new native broadleaved woodlands; protect and restore natural coastal processes; protect existing semi-natural habitats; target incentives for NbS to places where they can have most benefit; integrate NbS for climate into landscapes which are primarily devoted to agriculture or production forestry; carry out research and monitoring to fill evidence gaps; ensure mitigation and adaptation to climate change are planned together.” Natural England, Natural England Research Report (NERR094) Carbon storage and sequestration by habitat: a review of the evidence, second edition (20 April 2021) p viii: [accessed 10 January 2022]

179 HM Treasury, Autumn Budget and Spending Review 2021, HC 822 (October 2021) p 118—refers to £140 million being provided over the next three years for the Natural Capital and Ecosystem Assessment: [accessed 10 January 2022]

180 Natural England, ‘About us’: [accessed 10 January 2022]

181 Natural Agency, ‘About us’:; and Environment Act 1995 [accessed 10 January 2022]

182 Speech by Emma Howard Boyd, Chair of the Environment Agency at the ClimateExpo, ‘The crucial role of nature-based solutions in addressing the climate crisis’ (18 May 2021):; and the Environment Agency, ‘Use nature-based solutions to reduce flooding in your area’ (25 June 2021): [accessed 10 January 2022]. The RSPB’s report on the role of nature-based solutions in climate change adaptation policy includes examples of projects which have been used in the UK for climate change adaptation purposes. WWF-UK and RSPB, Nature based solutions in UK climate adaptation policy (2021): [accessed 10 January 2022]

183 Also Wales until 2013, and Scotland until 2019, when devolved public delivery bodies were set up.

184 Forestry Commission, ‘About us’: [accessed 10 January 2022]

185 Marine and Coastal Access Act 2009, Chapter 1

186 Marine Management Organisation (MMO), ‘About us’: [accessed 10 January 2022]

187 Tom McCormack, ‘The MMO and climate change’, Marine Management Organisation (MMO) (22 October 2021): [accessed 10 January 2022]

188 We heard from Dr Morecroft about successful, small scale, examples of collaboration between Natural England and the Environment Agency on saltmarsh restorations at Steart Marshes, Aldborough and Wallasea. Q 85 (Dr Mike Morecroft)

189 Q 92 (Dr Mike Morecroft, Richard Greenhous and Melissa Swartz)

190 Q 92 (Melissa Swartz)

191 Q 102 (Thomas Lancaster)

192 Oral evidence taken before the Environmental Audit Committee, 23 June 2021 (Session 2020–21), Q 213 (Sir James Bevan)

193 Q 102 (Thomas Lancaster)

194 Q 138 (Lord Goldsmith of Richmond Park)

195 Department for Environment, Food and Rural Affairs and Rural Payments Agency, ‘Environmental Land Management schemes: overview’ (15 March 2021): [accessed 10 January 2022]

196 This is a devolved area of policy, with Environmental Land Management schemes applying to England. Scotland has its own Agri-Environment Climate Scheme which covers and supports similar practices. Scottish Government, Rural Payments and Services, ‘Agri-Environment Climate Scheme’ (28 October 2021): [accessed 10 January 2022]

197 Area based payments are when a farmer receives a fixed subsidy per hectare of farmland they farm. Public money for public goods will pay land managers for practices that enhance and protect nature. Department for Environment Food and Rural Affairs, ‘Agriculture Bill to boost environment and food production’ (16 January 2020): [accessed 13 January 2022]

198 “We will maintain current average levels of investment in farming of £2.4 billion per year in England over the life of this Parliament. … Over this Parliament, we envisage spending 30% of the funding released for environment, climate and animal health and welfare outcomes on farm-level actions such as the Sustainable Farming Incentive. The remainder will be spent on locally tailored initiatives (such as through Local Nature Recovery and Countryside Stewardship) and landscape-scale interventions (such as Landscape Recovery and Nature for Climate projects). By 2028, we currently expect spending to be evenly split across farm-level, locally tailored, and landscape-scale investment. We will keep these allocations under review as we progress through the transition and learn more about the demand for and outcomes and value for money from each scheme.” Written evidence from Department for Environment, Food and Rural Affairs (NSD0042)

199 Department for Environment, Food and Rural Affairs, ‘Sustainable Farming Incentive: how the scheme will work in 2022’ (2 December 2021): [accessed 10 January 2022]

200 Department for Environment, Food and Rural Affairs, Environmental land management schemes: outcomes, policy paper, (6 January 2022), [accessed 11 January 2022]

201 The pilot scheme supported eight standards (activities) at three levels of ambition. The standards were: arable and horticultural land; arable and horticultural soils, farm woodland, hedgerows, improved grassland, improved grassland soils, low and no input grassland, and water body buffering.

202 Department for Environment, Food and Rural Affairs and Rural Payments Agency, ‘Environmental Land Management schemes: overview’ (15 March 2021): [accessed 10 January 2022]

203 Jason Beedell, ‘A quick guide to Defra’s Landscape Recovery Scheme’, Strutt & Parker (3 September 2021): [accessed 10 January 2022]

204 Department for Environment, Food and Rural Affairs, ‘Environmental land management schemes: outcomes’ (6 January 2022): [accessed 12 January 2022]

205 Written evidence from Department for Environment, Food and Rural Affairs (NSD0042)

206 Department for Environment, Food and Rural Affairs and Rural Payments Agency, ‘Environmental Land Management schemes: overview’ (15 March 2021): [accessed 10 January 2022]

207 Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery: more information on how the scheme will work’ (6 January 2022): [accessed 13 January 2022]

208 Department for Environment, Food and Rural Affairs, Environmental land management schemes: outcomes, policy paper, (6 January 2022), [accessed 11 January 2022]

209 See Box 1 for further detail. Parliamentary Office for Science and Technology, Local nature recovery strategies, PostNote 652, September 2021; and Department for Environment, Food and Rural Affairs, ‘September 2021: Nature and conservation covenants (parts 6 and 7)’ (6 September 2021)): [accessed 10 January 2022]

210 Department for Environment, Food and Rural Affairs, Local Nature Recovery Strategy pilots: lessons learned (12 July 2021): [accessed 10 January 2022]

211 HM Government, Net Zero Strategy: Build Back Greener (October 2021) p 168: [accessed 10 January 2022]

212 ‘Budget and Spending Review—October 2021: What you need to know’, HM Treasury (27 October 2021): [accessed 10 January 2022]

213 Over £500m of this is intended to be dedicated to tree-planting and £50m to peatland restoration, according to the Net Zero Strategy. HM Government, Net Zero Strategy: Build Back Greener (October 2021) p 168: [accessed 10 January 2022]

214 Department for Environment, Food and Rural Affairs, The England Trees Action Plan 2021–2024 (8 May 2021):; and Department for Environment, Food and Rural Affairs, England Peat Action Plan (18 May 2021): [accessed 10 January 2022]

215 Environment Agency, ‘How to apply for a natural environment investment readiness fund grant’ (10 November 2021): [accessed 10 January 2022]

216 Bidstats, ‘Big Nature Impact Fund—Request for Proposal’ (22 November 2021): [accessed 14 January 2022]

217 Department for Environment, Food and Rural Affairs, Environmental Land Management and Public Money for Public Goods (January 2021): [accessed 10 January 2022]

218 Q 102 (Richard Bramley)

219 Q 148 (Lord Goldsmith of Richmond Park)

220 Q 130 (Janet Hughes)

221 Q 15 (Professor Chris Collins)

222 Q 77 (Harry Greenfield); Q 101 (Thomas Lancaster); and Q 102 (Richard Bramley)

223 Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery Strategy pilots: lessons learned’ (12 July 2021):[accessed 10 January 2022]

224 Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery Strategy pilots: lessons learned’ (12 July 2021): [accessed 10 January 2022]. The pilots took place in Buckinghamshire, Cornwall, Cumbria, Greater Manchester, and Northumberland.

225 Activities that will be supported by the Local Nature Recovery schemes will include: restoring feeding, shelter and breeding areas for wildlife on farms; managing, restoring, and creating grassland, wetland, and heathland habitats, including species-rich grassland, ponds, lakes, and fens; managing and restoring upland and lowland peat and moorland; coastal habitats such as dunes, marshes, and shingles; managing and creating trees and woodlands, including agroforestry; restoring rivers, streams, floodplains, runoff management through buffer strips or vegetation in fields; and targeted reintroduction and recovery measures for particular wildlife species. Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery: more information on how the scheme will work’ (6 January 2022): [accessed 12 January 2022]

226 Q 101 (Thomas Lancaster); written evidence from National Association for Areas of Outstanding Natural Beauty (NSD0021); and written evidence from The National Trust (NSD0049)

227 Q 81 (Professor Mark Reed)

228 Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery: more information on how the scheme will work’ (6 January 2022): [accessed 12 January 2022]

229 Q 128 (Janet Hughes)

230 Q 101 (Thomas Lancaster)

231 Written evidence from the Landscape Decisions Programme Network (NSD0014)

232 Q 79 (Professor Rosemary Hails)

233 Q 2 (Sir Harry Studholme)

234 Q 102 (Richard Bramley)

235 Q 78 (Harry Greenfield); Q 104 (Richard Bramley)

236 Committee of Public Accounts, Environmental Land Management Scheme (Thirty-First Report, Session 2021–22, HC 639)

237 Written evidence from the NFU (NSD0017)

238 Q 103 (Richard Bramley)

239 Q 84 (Harry Greenfield)

240 Association of Local Government Ecologists (ALGE), Implications for Local Government of delivering the Environment Bill and the Government’s 25 year plan to improve the environment (January 2020): [accessed 12 January 2022]

241 Institute of Chartered Foresters, ‘Forestry skills crisis puts climate targets at risk’ (10 October 2021): [accessed 12 January 2022]; and Q 147 (Professor Gideon Henderson)

242 28 (Richard Lindsay)

243 Q 97 (Professor Selina Stead)

244 Q 102 (Richard Bramley, Thomas Lancaster)

245 Q 101, Q 102 (Thomas Lancaster)

246 Q 83 (Harry Greenfield)

247 Department for Environment, Food and Rural Affairs, ‘Environmental land management schemes: outcomes’ (6 January 2022): [accessed 12 January 2022]

248 Q 13 (Professor Chris Collins)

249 Q 84 (Harry Greenfield)

250 Department for Environment, Food and Rural Affairs, ‘Local Nature Recovery: more information on how the scheme will work’ (6 January 2022): [accessed 12 January 2022]

251 Department for Environment, Food and Rural Affairs and Victoria Prentis MP, ‘Future Farming Resilience Fund to open in August’ (13 July 2021): [accessed 12 January 2022]

252 Q 146 (Lord Goldsmith of Richmond Park)

253 146 (Lord Goldsmith of Richmond Park)

254 Q 146 (Lord Goldsmith of Richmond Park)

255 House of Commons Library, Tenant Farmers, Library Note SN/SC/1337, May 2010

256 Written evidence from the NFU (NSD0017)

257 Q 13 (Professor Chris Collins)

258 Q 141 (Lord Goldsmith of Richmond Park)

259 Q 80 (Professor Mark Reed)

260 Q 2 (Dr Bonnie Waring)

261 Q 13 (Dr Lisa Norton)

262 Q 6 (Professor David Coomes)

263 HM Treasury, Autumn Budget and Spending Review 2021, HC 822 (October 2021) p 72: [accessed 13 January 2022]

264 Environment Agency, Department for Environment, Food and Rural Affairs, and Natural England, ‘Innovative nature projects awarded funding to drive private investment’ (14 July 2021): [accessed 12 January 2022]

265 Dr Pat Snowdon of the Woodland Carbon Code identified factors for high-quality carbon standards: permanence; additionality; transparency through the use of a carbon registry; and independent validation to ensure that benefits are real and quantifiable. Q 51 (Dr Pat Snowdon)

266 Forestry Commission, ‘The Woodland Carbon Code scheme for buyers and landowners’ (9 July 2018): [accessed 12 January 2022]

267 UK Woodland Carbon Code (2019): [accessed 12 January 2022]

268 Quoted companies are required to report their greenhouse gas emissions, according to the Government’s methodology, as part of their annual directors’ report. Reporting remains voluntary for smaller companies and limited liability partnerships. Department for Environment, Food and Rural Affairs, ‘Measuring and reporting environmental impacts: guidance for businesses’ (published 9 April 2013, updated 31 January 2019): [accessed 12 January 2022]

269 Forestry Commission, ‘Woodland Carbon Guarantee’ (published 4 November 2019, updated 7 October 2021): [accessed 12 January 2022] In the most recently concluded auction, the average successful bid price for a Woodland Carbon Unit was £17.31. Forestry Commission, Guide to the Fourth Auction (2021): [accessed 13 January 2022]

270 UK Woodland Carbon Code, ‘Woodland Carbon Guarantee’ (2019):; and Department for Environment, Food and Rural Affairs, ‘Third Woodland Carbon Guarantee auction now open for applications’ (21 August 2020): [accessed 12 January 2022] [accessed 12 January 2022]

271 UK Woodland Carbon Code, ‘What are PIUs, WCUs and what can I say about them?’ (2019): [accessed 12 January 2022]

272 We heard from Dr Snowdon that, if woodland projects fail to perform as advertised, project managers are obliged to replant trees to achieve the promised number of woodland carbon units before they can be verified. Furthermore, establishing woodland counts as permanent land use change under UK law, so cutting down established trees requires a felling licence which obliges replanting elsewhere. The definitions of “permanence” and “additionality” in this context are set out by the Woodland Carbon Code. Q 64 (Dr Pat Snowdon)

273 . UK Woodland Carbon Code, ‘What are PIUs, WCUs and what can I say about them?’ (2019): [accessed 12 January 2022]

274 Q 63 (Dr Pat Snowdon, Dr Renée Kerkvliet-Hermans)

275 Q 67 (James Mansfield)

276 Q 67 (James Mansfield)

277 Comparing figures in Forestry Statistics 2020 and 2021—Forest Research, ‘Forestry Statistics 2021’ (2021):; and Forest Research, ‘Forestry Statistics 2020’ (2020): [accessed 12 January 2022]

278 UK Woodland Carbon Code, ‘UK Land Carbon Registry?’ (30 September 2021): [accessed 12 January 2022]

279 This can be compared to the Government’s target of 35,000 hectares of peatland restoration by 2025, although not all peatland restoration projects will be registered under the code. Carbon Brief, ‘Analysis: How will England’s strategies for trees and peat help achieve net zero by 2050?’ (19 May 2021): [accessed 12 January 2022]

280 Q 67 (James Mansfield)

281 Q 67 (David Young)

282 Q 55 (Dr Pat Snowdon)

283 Q 55 (Annette Burden)

284 Q 55 (Annette Burden)

285 Q 55 (Annette Burden)

286 Q 55 (Dr Pat Snowdon)

287 Environment Agency, Department for Environment, Food and Rural Affairs, and Natural England, ‘Innovative nature projects awarded funding to drive private investment’ (14 July 2021): [accessed 12 January 2022]

288 Q 144 (Lord Goldsmith of Richmond Park)

289 Q 24 (Professor Chris Evans)

290 Q 3 (Sir Harry Studholme)

291 Q 51 (Dr Renée Kerkvliet-Hermans)

292 Q 67 (Helen Avery)

293 51 (Dr Pat Snowdon)

294 Camilla Hodson and Laura Noonan, ‘Cost of neutralising carbon emissions soars as demand escalates’, Financial Times (6 January 2022): [accessed 14 January 2022]

295 UK Woodland Carbon Code, ‘What are PIUs, WCUs and what can I say about them?’ (2019): [accessed 13 January 2022]

296 ‘Net-zero carbon pledges must be meaningful to avert climate disaster’, Nature (31 March 2021):–021-00864-9 [accessed 13 January 2022]

297 ‘Carbon offset market needs radical reform’, UCL News (4 December 2020): [accessed 13 January 2022]

299 David Sheppard and Camilla Hodgson, ‘UK carbon price trades at £50 as market opens for first time’ Financial Times (19 May 2021): [last accessed 14 January 2022]

300 Q 67 (James Mansfield)

301 Shadia Nasralla, ‘First reality check launched for corporate climate claims’, Reuters (28 October 2021):–10-27/ [accessed 13 January 2022]

302 Science Based Targets, ‘The Net-Zero Standard’: [accessed 13 January 2022]

303 Q 144 (Lord Goldsmith of Richmond Park)

304 Q 69 (David Young)

305 Financing UK Nature Recovery, Recommendations and roadmap (2021): [accessed 13 January 2022]

306 Q 70 (David Young)

307 Carbon Brief, ‘COP26: Key outcomes agreed at the UN climate talks in Glasgow’ (15 November 2021) Article 6 section: [accessed 13 January 2022]

308 Q 124 (Professor Gideon Henderson)

309 Q 81 (Professor Rosemary Hails)

310 Q 103 (Richard Bramley), Q 78, Q 81 (Harry Greenfield, Professor Rosemary Hails)

311 Written evidence from the Sustainable Soils Alliance (NSD0033); Q 105 (Thomas Lancaster)

312 International Union on the Conservation of Nature, ‘For Buyers’: [accessed 13 January 2022]

313 Q 66 (David Young)

314 Q 55 (Annette Burden)

315 Q 51 (Dr Renée Kerkvliet-Hermans)

316 Q 66 (James Mansfield)

317 Q 152 (Lord Goldsmith of Richmond Park)

318 Q 77 (Harry Greenfield); Q 146 (Lord Goldsmith of Richmond Park)

319 Committee on Climate Change, Land use: Policies for a Net Zero UK (23 January 2020) p 9, 30: [accessed 17 December 2021]

320 The Committee has specific progress metrics for reducing meat consumption, food waste, and livestock numbers and increasing yield per hectare. Committee on Climate Change, Progress in reducing emissions, 2021 Report to Parliament (June 2021) p 119: [accessed 7 January 2022]

321 HM Land Registry, ‘About us’: [accessed 5 January 2022]

322 Tim Adams, ‘Who Owns England? by Guy Shrubsole review – why this land isn’t your land’, The Guardian (28 April 2019): [accessed 13 January 2022]

323 Guy Shrubsole, Who owns our carbon? from Who Owns England? (November 2021): [accessed 13 January 2022]

324 Ministry of Defence, ‘MOD Land Holdings: 2000 to 2021’ (27 May 2021): [accessed 13 January 2022]

326 Q 144 (Professor Gideon Henderson, Lord Goldsmith of Richmond Park)

327 Q 144 (Lord Goldsmith of Richmond Park)

328 Q 149, Q 152 (Lord Goldsmith of Richmond Park)

329 Q 149 (Lord Goldsmith of Richmond Park), Written Evidence from Department for Environment Food and Rural Affairs (NSD0042)

330 Q 150 (Lord Goldsmith of Richmond Park)

331 Q 149 (Lord Goldsmith of Richmond Park)

332 Q 77 (Harry Greenfield)

333 Committee of Public Accounts, Environmental Land Management Scheme (Thirty-First Report, Session 2021–22, HC 639)

334 Liaison Committee, New committee activity in 2022 (4th Report, Session 2019–21, HL Paper 97)

335 Liaison Committee, New committee activity in 2022 (4th Report, Session 2019–21, HL Paper 97)

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