The National Audit Office has raised wide-ranging concerns warning that without clear plans and goals, the Government risks failing to achieve its 25 year environmental targets set out in its 25 year plan.

The warnings come in a new report published by the NAO today - Achieving government’s long-term environmental goals which examines how government has set itself up to deliver its long-term environmental goals.

The NAO’s aim in the report has been to highlight the most significant potential strengths and areas for improvement, as well as key risks that government will need to manage.

According to the NAO, while the government’s 2018, 25 Year Environment Plan brings together a number of government’s environmental commitments and aspirations in one place, “it does not provide a clear and coherent set of objectives.”

The NAO report says:

“The headline ambitions in the 25 Year Environment Plan include a number of specific and measurable objectives, such as the ambition to achieve zero avoidable waste by 2050, and to meet legal emissions targets for air pollution.

“However, these form part of a complex mix of aspirations and policy commitments for action, with varying and often unclear timescales.”

The NAO has flagged up that it is also difficult to determine how the ambitions relate to pre-existing national, EU and international environmental targets, commenting:

“In October 2018, government agreed to publish an audit of this comparison “in due course”, which it has yet to do.”

Achieving government’s long-term environmental goals

Commenting on the Environment Bill developed by the Department for Environment Food and Rural Affairs which was introduced to Parliament in January 2020, the NAO is warning:

“However, government has yet to set a clear course for the development of a coherent and complete set of environmental objectives, and for a full set of costed delivery plans. Government has not yet decided whether or how it will integrate and align the complex mix of legislative and non-legislative environmental commitments that already exist with the new targets required under the Environment Bill.”

The Bill requires the government to set at least one new long-term target in each priority area by October 2022. Together these must constitute a “significant improvement” to the natural environment in England.

The NAO is flagging up that while Defra has started to assess potential gaps against government’s environmental ambitions, it has not set a timetable for concluding the analysis or for developing long-term delivery plans for each of the goals.

“This means that neither Defra nor HM Treasury yet has a good understanding of the long-term costs involved in delivering the Plan as a whole. Given the timescales involved, delivery plans will need to be flexible enough to accommodate different scenarios, with associated costings recognising the underlying uncertainties. However, they are still important as otherwise there are risks that decisions about funding allocations are made in a piecemeal way, rather than on the basis of a strategic view of long-term priorities,” the report says.

The NAO also draws attention to the following inconsistency – namely, that while the 25 Year Plan lists resource efficiency and waste reduction as two separate environment goals, the Bill treats them as a single environmental area.

The NAO has made a number of key recommendations for the government to:

• clarify its environmental ambitions so that by the time it puts forward new legislative targets (in October 2022), these are part of a coherent suite of objectives that set specific and measurable ambitions for medium-term (2030) and long-term (2040 onwards) outcomes for each of its
• environmental goals;
• develops a delivery plan for how the planned outcomes are to be achieved. This should set out the firm and funded actions that government has planned, and explicitly state whether government expects these are likely to be sufficient to put progress on track to meet the outcomes.
• where there are gaps, government should set out how and when it expects to make decisions to fill these.
• mapping out the areas where other departments have a critical role to play;
• establishing clear expectations for these departments’ contributions to improving performance, and how this will be measured and monitored; and
• strengthening coordination and oversight arrangements where appropriate, particularly for climate change adaptation and domestic biodiversity

The NAO is calling for the plan to set interim milestones by which progress can be monitored, covering medium-term outputs (up to 2030).

It also wants to see an assessment of the short-, medium- and long-term costs of this delivery plan to ensure that Defra and HM Treasury have a shared view of the associated costs and how these might be financed.

The NAO has acknowledged that the Government’s capacity to take forward environmental work has been affected by the COVID-19 pandemic over the past six months, but points out that “progress was already slower than government had intended and that prior to the pandemic, Defra had already encountered delays.”

Defra had originally anticipated producing more detailed proposals for some of the new measures in the resources and waste strategy in early 2020. The NAO report says:

“Given that the Plan was published three years after government accepted a recommendation to develop a 25-year plan to deliver its environmental ambitions, we would have expected it to already have fairly well-developed delivery plans.”

The NAO is recommending that Defra maps out the most significant interdependencies between the goals in the 25 Year Environment Plan and sets out how decisions about any significant trade-offs will be made, and by who.

Government’s arrangements for joint working between departments on environmental issues are“patchy”

Describing the Government’s arrangements for joint working between departments on environmental issues as “patchy”, the NAO said it had found:

“..a mixed picture in terms of the extent and strength of arrangements between different departments on specific environmental issues, and no clear indications of senior ownership outside Defra and its arms-length bodies for the Plan as a whole….

“Arrangements for engagement on adaptation to climate change have been weak. The Domestic Adaptation Board has met infrequently: twice in the past three years. There are no regular, formal arrangements at all for Defra to engage other departments on the goal to protect and restore wildlife in England…..

“…No other departments, apart from Defra, are represented on the main oversight committees for the Plan, and government has not developed other ways to ensure senior cross-government ownership of the Plan as a whole nor to set clear accountabilities for their contribution to performance.”

The NAO is recommending that Cabinet Office and Defra should review and improve arrangements for engaging departments outside Defra on the Plan.

Skills and resource gaps could inhibit government’s progress in achieving environmental ambitions

The report also draws attention to the possibility that skills and resource gaps could inhibit government’s progress in achieving environmental ambitions and identifies risks in three key areas:

• Among local government - local authorities have a critical role to play on a range of environmental issues, including to improve local air quality and to ensure that developments in their local area support the recovery of nature. The COVID-19 pandemic is putting pressure on local authorities’ resources, and they will need access to the right expertise, including ecological expertise.

• Within Defra - Defra will need to ensure that it has people with the right skills and experience to oversee such a complex programme, and that it handles turnover well: since the Plan was published it has had three different senior responsible owners.

• Among arm’s-length bodies - three of Defra’s arm’s-length bodies raised concerns with us around funding or skills shortages within their organisations or within the wider supply chain that they will rely on to deliver environmental improvements

The NAO is recommending that Defra, working with Cabinet Office and HM Treasury develops a strategy for ensuring that the right skills and resources are available to meet government’s environmental ambitions. This should include:

• published analysis of how government will ensure that key delivery partners, including local authorities and Defra’s arm’s-length bodies, have appropriate funds to fulfil their environmental responsibilities; and
• a review of the factors that led to high turnover among the senior responsible owners for the Plan, and how these factors may be mitigated in future.

More action needed on monitoring progress

The NAO also wants to see more action being taken on monitoring progress, saying:

“Defra’s approach to monitoring progress across the goals is developing but has some serious gaps. Defra started monitoring progress by tracking a subset of priority actions, but then moved to ad hoc, narrative updates on specific issues.”

“It has yet to specify which of its oversight groups is responsible for setting action plans and requiring improvements if performance against any of the goals is not on track.”

The report recommends that government sets a deadline for securing a full set of outcome-focused environmental indicators, with data, and that Defra’s Environment Committee monitors progress against this deadline, taking swift action if things fall behind.

Government does not yet monitor total spend on delivering its environmental goals

The NAO is warning that as yet the Government still does not monitor total spend on delivering its environmental goals.

The report says that since 2018, government has announced funding for a wide range of initiatives to deliver its environmental goals, including a £640 million Nature for Climate Fund to increase tree planting and restore peatland, £475 million on air quality measures and up to £25 million to create a new ‘nature recovery network’ in England.

However, while Defra started an analysis of spend by environmental goal as part of its preparations for the 2020 Spending Review, it does not yet have a good breakdown of annual costs and “there is no single point of responsibility for monitoring overall environmental spend or costs on an ongoing basis, which is likely to limit government’s ability to assess and take action to improve the value for money of the portfolio of initiatives as a whole.”

The NAO recommends that Defra, working with Cabinet Office and HM Treasury, monitors annual costs and spend on key environmental initiatives across government, alongside the benefits they achieve, as part of developing performance reporting against the Plan.

The report goes on to warn that public reporting of progress is not well developed, although Defra has published two annual progress reports on the Plan. The Natural Capital Committee published its final review of Defra’s progress reports in October 2020.

According to the NAO, the Natural Capital Committee, responsible for scrutiny of government’s public reporting against the Plan, has “raised concerns about the quality of these annual reports, and concluded that the government is not on course to achieve its objective to improve the environment within a generation.”

The proposed new Office for Environmental Protection (OEP), the new environmental watchdog which the Environment Bill will establish, will scrutinise progress from 2021.

The NAO report flags up the fact that the auditor has previously highlighted the need for the OEP to have appropriate resources, strong leadership, and sufficient independence to provide effective scrutiny over environmental metrics.

Government had planned for the OEP to be operational by the end of the transition period, from January 2021, but it now expects that it will not be formally established by this time and that it will be a few more months before it is fully operational .

The NAO is reiterating its recommendation that the government should continues to strengthen safeguards for OEP’s independence, by developing a clear framework document for the terms of its relationship with Defra, and by setting out Parliament’s ongoing role in reviewing OEP’s funding and leadership.

The NAO concludes:

“It is now nine years since government first set an ambition for this to be the first generation to improve the natural environment in England, and there is still a long way to go before government can be confident that it has the right framework to deliver on its aspirations and ensure value for money from the funding it has committed to environmental projects.

“We recognise that the demands of responding to the COVID-19 pandemic over the past six months have slowed the momentum it had started to develop, but progress was already slower than government had intended.

“Environmental issues are broad, inter-related and complex, so these are not straightforward challenges to address, but government needs to pick up the pace if it is to improve the natural environment within a generation.”

According to the NAO, the Government’s ‘net zero’ greenhouse gas emissions target is central to its environmental goal of mitigating climate change- the auditor is also separately preparing a companion report on how government is organised to deliver it.

Gareth Davies, head of the NAO commented:

“The government wants this to be the first generation to leave the natural environment in England in a better state than it inherited. However, it is now nine years since the government set this ambition and it still does not have the right framework to achieve it.

“Some progress has been made on elements of the Environment Plan but significant action is needed across national and local government, working with business and the public, if the environmental goals are to be met.”

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