We welcome the commitment (Commitment 16) to double the number of farms providing sufficient year-round resources for farm wildlife by December 2030, to achieve 7% of land protected for nature, compared with 2025. The role of Environmental Land Management (ELM) schemes in delivering this and other EIP targets is well recognised. However, this commitment requires increased and longer-term investment beyond what has already been promised here, especially given the major climate challenges ahead for farmers. Our analysis suggests that at least £3.1 billion needs to be spent on nature-friendly farming and land management annually in England to meet the Government’s targets – far more than the £2.7 billion a year actually allocated. 

Within ELMS, the Sustainable Farming Incentive (SFI) must be targeted to bring about real, lasting system change. There must be coherent packages of actions, not piecemeal ones, that all farmers can access - and get independent advice to deliver on – to help farm wildlife, store carbon, tackle water issues, air pollution and nature’s recovery everywhere. In order to contribute to the achievement of 30x30, the Landscape Recovery scheme will need sufficient budget, well designed contracts and long term finance. 

As farming is responsible for significant ammonia and nitrous oxide air pollution, we welcome the commitment (Commitment 26) in the EIP to tackle this. However, we can see no actions in the Delivery Plan to deliver towards the commitment.  

The EIP commitment to consult on the extension of environmental permitting for dairy and intensive beef farms is a positive step. This should be undertaken urgently given their impact.  We urge the government to reduce the size of pig and poultry units that require permits so more come under the permitting regime and to account for the wider environmental impacts associated with feed production and off-site excreta use associated with production units. 

The Plan also proposes a 14% contribution from agriculture to the 40% target of reduction in total nitrogen, total phosphorus and sediment water pollution by 2038, with agri-environmental schemes and the land use framework highlighted as key delivery measures. We urge the need for increased budget and support to push these schemes forward alongside better regulation of the supply chain to support, not hinder, faming’s transition to a nature-positive industry.  

We welcome continued funds for palludiculture on peat soils; however, the Nature for Climate Peatland Grant scheme will end in March 2027. Peatland restoration will then be delivered by Landscape Recovery and Countryside Stewardship, but we are concerned that adequate, long-term funding is still not confirmed and this is essential to support the large-scale restoration projects and future restoration projects needed, alongside the many other outcomes to be delivered by ELM schemes. This commitment to end the use of peat in horticulture must be delivered swiftly. The original targets were made in 2011 and, fourteen years later, we are still waiting to see an end to the ongoing damage to climate and nature from this harmful practice. This is an absurd and unjustifiable delay.  

The Plan contains lots of positive words about actions already in progress. However, many of these commitments lack solid timelines creating uncertainty as to when they will be implemented. Without implementation timelines, promises risk being more empty words for nature.  

Commitment 7 recommits to effectively conserving and managing 30% of UK’s land by 2030. This is welcome. However, we are disappointed to see the interim targets on Sites of Special Scientific Interest (SSSIs) have been pushed back. Commitment 8 - to have 50% of SSSI features with ‘actions on track’ to achieve favourable conditions – was 2028 but has now been delayed until 2030. The EIP23 interim target for all SSSIs to have an up-to-date condition assessment by 2028 has been delayed until 2032. However, a SSSI feature can only be judged to have ‘actions on track’ if it has an up-to-date condition assessment. This will make it harder to achieve 30by30 because only those SSSIs with ‘actions on track’ should count towards 30by30. There is no mention of how Defra intends to meet the condition assessment monitoring target. 

Moreover, the action plan to support work towards the 30 by 30 commitment has been delayed once again, and there is no indication within the EIP about what the Government intends to do about the criteria, the self-assessment process, and reporting internationally on our progress under the Global Biodiversity Framework. . This has all been delayed to the 30x30 action plan which is expected “in due course” – no real dates have been given, which means that targets are woolly and unclear. 

Commitment 67 is for terrestrial protected site designation and management to be more dynamic and adaptive to the changing climate. This is welcome and something we have been pressing for. It is important to maintain protected sites as core high-value nature sites whilst accepting that some features may be lost to climate change impacts. However, any flexibility with regard to changing features must only be used in those circumstances where it can be proven that climate change and/or extreme events have caused the change to a feature and not used where a site has deteriorated due to lack of appropriate management. This could provide a license for neglect.  

Protected Landscapes (National Parks and National Landscapes) are expected to “deliver half of our statutory target to restore or create wildlife-rich habitat”. However, the promise to reform the statutory purposes on nature’s recovery has been downgraded to “Champion Protected Landscapes by refreshing our national vision”. At the same time, there is also a commitment to “strengthen legislation to give National Parks and National Landscapes at clear mandate to widen the public’s access to nature by the end of this Parliament”. At the moment, the Sandford Principle (Environment Act 1995) – for National Parks – means that is where there is a conflict between the statutory purposes of National Parks, any relevant authority “shall attach greater weight to the purpose of conserving and enhancing the natural beauty, wildlife and cultural heritage of the area comprised in the National Park”. At a time when biodiversity continues to deteriorate, this directive steer to not only conserve, but also to enhance, nature and wildlife must be maintained.  

The EIP contains positive commitments and actions on trees, but these are not matched by equivalent levels of commitment towards other key habitats. There is also a worrying commitment to increase the proportion of conifer species contributing to national tree planting (#52) and an action on Defra to collaborate with LNRS to “encourage productive woodlands”. That wasn’t the intention of LNRS. IUCN guidelines are clear that intensive commercial forestry plantations are excluded from 30by30, due to their low biodiversity value. Nature in many parts of the country is only just recovery from damaging 20^th century forestry policy, focussed around fast growing, nature-light conifers. Ministers risk repeating this mistake.  

It is good to see recognition of the important role LNRS can play in contributing to EIP delivery and the commitment to bring forward the legal requirement from the Levelling Up and Regeneration Act 2023 to ‘take account’ of LNRS. There is however a worrying lack of a timeframe for this.  

There is welcome recognition for the role of the Land Use Framework. Unfortunately, this needs clear timelines for publication and a solid plan to outline how it will be effectively integrated into the wide range of land use policy areas. Without these commitments, it remains unclear if the potential of the LUF will be realised.  

There is welcome recognition of the role of Biodiversity Net Gain (BNG) in securing development that works for nature. The EIP reiterates the current timetable for bringing forward BNG for Nationally Significant Infrastructure Projects (NSIPs) by May 2026. However, with rumours that the Government may announce wider exemptions to BNG in the weeks ahead, the role of BNG in supporting the emerging nature market – and wider nature recovery – is under threat. If BNG is eviscerated, all hope of delivering nature recovery alongside new housing will be lost.  

Cleaning up rivers, lakes and seas has long been promised by the Government so the section on Goal 3: Water, is likely to be heavily scrutinised. It contains a welcome recommitment to changes announced following the publication of the Independent Water Commission's report including introducing a regional element within the new water regulator to ensure greater local involvement in water planning. It also highlights recent beneficial changes such as a ban on plastic-containing wet wipes, expected to come into force in spring 2027.  

Some of the most significant changes from EIP’23 are that interim targets which were included then as aspirations are here committed to as firm intentions; particularly in the area of water resources (leakage, household and non-household water use reduction). It is concerning, however, that prior interim targets have in some cases been extended, due to insufficient progress to date. It is essential to ensure that the processes identified for keeping these on track – largely ‘holding water companies to account’ but also ‘enabling infrastructure delivery’ (if done sustainably) are both progressed. There are welcome indications of action on chemical pollution (e.g. sludge regulation) but, disappointingly, outcomes are as yet unspecified.  

The section on chalk streams is welcome in terms of keeping a focus on these globally-rare and vulnerable ecosystems, but seems to be mainly recommitting to existing initiatives. This includes investing in chalk stream restoration ‘through the Water Restoration Fund and Water Environment Improvement Fund over the next two years', and continuing with water company flagship projects, PR24 investment especially for Storm Overflows, delivering under the National Framework for Water Resources and progressing abstraction reduction. Whilst these are good recommitments, these add little to our existing toolbox for chalk stream conservation, so it will be important to ensure that other expected changes (planning protections and a consultation on designation chalk streams as irreplaceable habitat) are forthcoming.  

Frustratingly, marine feels like  an afterthought in the EIP, with only two commitments. The actions to deliver these commitments are just delayed actions that should have been instigated already. Our increasingly congested, nature-poor, overheating seas need more than reheated policies.  

This is particularly the case for commitment 17, which is to make sure at least 49% of Marine Protected Area (MPA) protected features are in a favourable condition and at least 46% in a recovering condition by December 2030 (Environment Act interim target). Defra cannot assess progress against these targets if there is no monitoring of MPAs undertaken to provide the data needed. The Wildlife Trusts’ MPA recovery check tool shows that we are a long way off achieving this target and that there is a significant lack of up-to-date data to inform on condition status. Natural England is currently only funded to monitor one MPA per year. This is an appalling state of affairs. 

It’s good to see dates provided for the fisheries management actions to better protect MPAs but these are rolled over from previous targets for both stage 3 (bottom-towed gear management in offshore MPAs with seabed features) and stage 4 management measures for mobile species in Special Areas of Conservation (SACs) which should have been in place by end of 2024 so are well overdue. Highly Protected Marine Areas (HPMAs) were designated three years ago and still have no management measures for fishing activity in place. So whilst it’s good to have new deadlines, these are still a long way off and do not foster the urgency required. The MPA review was promised in January 2025, and now has a target date of end of 2028. 

There is a recognition that offshore wind development will impact MPAs but the comment in the Annex which states "The inclusion of 5% of [MPA] features neither in favourable or recovering condition has been introduced to support the government’s wider commitments, such as the net zero target"  appears to almost to put a target on the damage as a sacrificial percentage of the network that can be impacted for growth. 

Under the fisheries commitments, there are no deadlines to rebuild stocks and far too much reliance on Fisheries Management Plans to achieve the actions required, but these plans have limited ambition or teeth and are predominantly industry-led.