Jeremy's Blog 26th April 2024: Targets - Gestures Real or Straightjacket

This article by Jeremy Moody first appeared in the CAAV e-Briefing of 25th April 2024

Targets are everywhere in modern government. In principle, they can set a discipline to achieve results, measured and monitored for management. Sometimes, so many are set that they confuse or even counter each other; some are badly set with perverse results. Some targets seem set just as a gesture, with magical thinking that a target is an answer not then needing action, role playing in response to pressure – even a displacement activity - but becoming totems for interest groups.

The Scottish Government’s public abandonment of its target to cut greenhouse gas emissions by 75 per cent by 2030 is an example of a target that has long been unrealistic, the only surprise being the need to make it now. It has been in plain sight that the grand rhetoric of climate virtue had no substance, at least as regards agriculture – while climate change advances regardless.

While the December 2020 Climate Change Plan Update 2018 to 2032 expected agriculture to make a 31 per cent cut by 2032, the August 2021 Consultation on the Agricultural Transition already said that the main farmer-led group proposals could only achieve no more than 40 per cent of that, even if all recommendations were fully implemented by farmers, saying that:

“highlights the very substantial remaining challenge that a very significant reduction of at least 1.4 MtCO2e or 60% of GHG emissions is still to be addressed.”

The February 2022 Vision for Agriculture accepted the Green Finance Institute’s assessment that Scotland was £20bn short of funding its 2030 target, a figure that the Scottish Government has quoted since. The sands of time were running but nothing else moved. With the time shortening, the gap between aspirational statements and hard policy delivery is now laid bare. The change that would now be required is too abrupt to have useful meaning, defeating the point of an interim target aiding delivery.

Demanding environmental targets have also been set in England. It may be hard to meet the species abundance targets in the short timescales stated. The water quality ones are now framing policy as we move from slurry store grants towards further regulation – the Wye Valley Action Plan and Poole Harbour catchment measures perhaps setting the course.

The SSSI improvement targets set in the Environment Improvement Plan 2023 may be a greater challenge for affected owners as Natural England will be held to account for them. SSSI designation (often in very broadbrush terms) and the associated lists of Operations Requiring Natural England’s Consent (ORNECs) have not yet been widely seen for the true scale of management control they can take from owners and farmers – this may become more stark.

With a 2042 target for 75 per cent of SSSIs to be in (possibly novel) good condition, one interim target is to:

“have actions on-track to achieve favourable condition on 50% of SSSI features by 2028”.

With the force of an obligation imposed on an arm’s length body by Government, Natural England is required to drive change in farming and land management, based on its own monitoring and assessment but with the changing backdrop of climate change and limited tools at its disposal.

Beyond this lies the extraordinary international “30 by 30” commitment, that 30 per cent of land be managed for nature by 2030 in each part of the UK. Holland, for which simple arithmetic makes this difficult, is understood to be asking other EU countries to carry some of its load. Other countries, often large ones, may already meet this but England is 6,000,000 acres short with just six years to go and other competing uses for land. Without very abrupt change, it looks impossible but has already, for example, been cited in extending the West Penwith SSSI.

Scotland, nearer this target, is now proposing that NatureScot use Land Management Orders to require active change on identified land outside SSSIs with powers possible from 2025. That eats further into the rights of owners, joining the new announcement of a possible carbon tax on large landholdings to prompt tree planting and peatland restoration.

Targets, realistically set and even stretching, can be a powerful discipline for effective policy delivery. They are devalued where they are seen to be aspirational signaling without substance. Governments may sometimes wear their own targets lightly but targets become part of the purpose of bodies required to deliver them with mandates that might not recognise other interests, a mechanical straightjacket precluding proper policy marking.