Starmer’s nature plan is pathetic. Burnham must do better

Today's 30by30 Delivery Plan isn't a plan, and it won't deliver 30by30.

As Edmund Blackadder would say: oh god, it’s pathetic.

In its dying days, Starmer’s government has just published a new plan for how it will protect and restore 30% of land for nature in England: its ‘30by30 Delivery Plan’. The problem is, it’s not a plan, and it won’t deliver 30by30. It is, in fact, one of the weakest and most pathetic government documents I’ve read in a long time.

Nature is in crisis. Westminster journalists tend to dismiss the natural world as a fringe concern and an impediment to growth; but I think that the unravelling of the web of life is quite important, actually. Earlier this year the government reluctantly published a supressed report on the nature crisis by the Joint Intelligence Committee, which stated that “global ecosystem degradation and collapse threaten UK national security and prosperity”. In our own country, the warning lights are flashing red: we have destroyed 99% of the UK’s fenland habitat, 97% of wildflower meadows, and over a third of our ancient woodland. As a nation, we love David Attenborough, and are about to put wildlife on our banknotes – but we are also one of the most nature-depleted countries on Earth.

In 2020, to try to do something about this, the UK Government joined world leaders in signing up to the ‘30by30’ commitment: a pledge to protect and restore 30% of the planet for nature by 2030, and for each nation to do likewise within their own territories. This went on to be adopted as a formal UN target agreed by countries around the globe. Westminster has responsibility for nature within England only – in the rest of the UK, it’s the purview of the devolved administrations – so for the government to deliver 30by30 means protecting and restoring 30% of England for nature by 2030.

However, today’s 30by30 Delivery Plan utterly fails to do this. Instead, it:

· Admits that only 7% of land in England is currently being properly protected and looked after for nature;

· Tries to claim that 32% of England “has the potential to” contribute to the target (based on some heroic assumptions, which I’ll explore below);

· Announces no new policies to turn this potential into reality; and instead,

· Issues a truly pathetic plea for help from landowners and the public – in an effort to pass the buck for the government’s failure to act.

If Keir Starmer and his environment ministers were hoping this to be some sort of legacy, before Andy Burnham takes over at the end of this week, it’s a truly sorry one.

Let’s dig into what the 30by30 delivery plan says, how we got to this sorry state, and what Andy Burnham’s government needs to do to fix things when he takes the reins.

We need to protect 30% of England. We’re currently at 7%.

How might England reach 30by30 on land? This is something the UK Government have had six years to think about, ever since they signed up to it in 2020. Unfortunately, today’s 30by30 Delivery Plan offers few answers.

Firstly, the 30by30 Delivery Plan admits that only 7% of England currently meets the criteria for 30by30. This is a stat that civil servants in the Department for the Environment, Food & Rural Affairs (DEFRA) first calculated almost two years ago, in October 2024, and yet no new policies seem to have been developed in that time to remedy the situation. The only innovation is that the Delivery Plan irritatingly calls this the ‘Gold tier’, as if it’s some sort of nature Olympics. (I can just see Blackadder rolling his eyes with contempt.)

What makes up that 7% figure? Essentially, Sites of Special Scientific Interest (SSSIs) – the backbone of England’s system of nature conservation. SSSIs have their flaws, but they’re the main means by which natural habitats are given legal protection (many of them bolstered by being overlaid with European site protections called SACs and SPAs – we conservationists love our acronyms). There’s also National Nature Reserves, a smaller category of the very best sites, but almost all of these are also underpinned by SSSI protections; and a small amount of publicly-owned broadleaved woodland that’s being managed for nature. But mostly it’s SSSIs.

DEFRA accept that not all SSSIs are in good nick, and that therefore only those assessed as being in ‘Favourable’ and ‘Unfavourable Recovering’ condition should count. Many environmental NGOs argue that even this is too generous, and that only those SSSIs in Favourable condition should be eligible – reducing the figure to more like 3%.

To show you just how little of England is properly protected for nature, here’s a map of the SSSIs in Favourable (Green) and Unfavourable Recovering (Yellow) condition:

So, how does the 30by30 Delivery Plan say we’ll make up the remaining 23% in… er… 4 years?!

Surprise, surprise: it doesn’t!

Instead, it waffles on about ‘Silver’ and ‘Bronze’ tiers of land that could, might, maybe count towards 30by30. If we’re lucky. Its assessment (based on an earlier methodology document) that 32% of England could count towards the target is based on heroic assumptions - such as adding in a bunch of land that isn’t currently doing much for nature at all. It’d be great if it was, but we’d need new policies to make this happen; and those are decidedly absent from the plan.

The overwhelming emphasis, instead, is on landowners bringing forward land voluntarily to help contribute towards the government’s 30by30 target. As the Ministerial foreword says: “we cannot deliver 30by30 alone. Success depends on the actions of landowners, farmers, conservation organisations, businesses, communities, and individuals across the country.”

This, in my view, is a huge abdication of responsibility by ministers. Sure, there are some private landowners and community groups doing great things for nature. But if they’re already doing so, what additional benefit does the government bring just by cataloguing this activity? This all smacks of passing the buck – asking others to do the work when the State, with all its powers, knows it’s going to miss a looming deadline and has failed to get its act together. It seems like Ministers are saying: Ask not what your government can do to protect nature – ask what you can do to protect your government from embarrassment.

What’s more, this plea for help won’t result in England miraculously reaching 30by30 on time. If loads of private landowners were already restoring nature, we wouldn’t be in a nature crisis. The reality is that many landowners and farmers across England have been actively destroying habitats and wildlife for many decades, through activities like industrial agriculture, modern plantation forestry, and intensive shoots. Up until quite recently, such activities were encouraged by government subsidies. It has been government policies to curtail such destructive activities by landowners, and incentivise or mandate nature recovery, that has led to more land being protected and restored for nature. For the government to expect to meet its 30by30 goal through landowners voluntarily bringing more land forward is as unrealistic as it is irresponsible.

A cunning plan to actually reach 30x30

What makes today’s 30by30 Delivery Plan even more frustrating is how it ignores previous more sensible suggestions for how to meet the 30by30 target. Here are a set of ideas for how to reach the target; together they comprise a plan so cunning, you could put a tail on it and call it a weasel.

1) Do far more to restore nature in England’s National Parks and National Landscapes

· Back in 2020, when the Government first signed up to 30by30, Downing Street suggested that 26% of England already counted towards the target, because that was the area covered by National Parks and National Landscapes.

· Environmental NGOs rightly kicked off about this, because many of our National Parks are in a terrible state for nature. (Just look at how overgrazed Dartmoor is, or how much of the North York Moors is covered by grouse shoots.)

· DEFRA eventually relented and in its Nature Recovery Green Paper (March 2022), accepted that “…we know that they [National Parks & National Landscapes] must do more to drive the recovery of nature. Under their current statutory purposes, level of protection and management, it is our view that they cannot be said to contribute towards 30 by 30 at this time.”

· Following much civil society campaigning, the current Labour government announced in December 2024 that it would update the statutory purpose of National Parks and National Landscapes to include nature recovery. Which is great! However, to do this requires primary legislation – a Bill to pass through parliament. There has been neither sight nor sound of any such legislation since this announcement was made to much fanfare. Can we have the Bill, please?

2) Give the Forestry Commission an updated statutory purpose to restore nature

· DEFRA’s 2022 Nature Recovery Green Paper also suggested that the Forestry Commission’s public forest estate could do more to meet 30by30.

· Again, DEFRA accepted that legislative changes would be needed to make this happen, stating: “The UK Government forestry body’s statutory duties on forestry currently prioritise timber production and the conservation of natural beauty areas… we must ensure these duties better reflect the environmental and social importance of woodlands, and we are considering introducing a new duty to protect nature and promote biodiversity”.

· There has, however, been no such change in the Forestry Commission’s statutory duties, which were last properly updated in the Forestry Act 1967 – meaning the FC’s main duty remains “promoting the interests of forestry, the development of afforestation and the production and supply of timber and other forest products”.

· If the government wants the Forestry Commission to help meet 30by30 and ensure its vast landholdings are managed for nature, it will need to pass legislation updating its statutory purposes to prioritise nature recovery.

3) Introduce mandatory nature reporting by landowners

· Rather than rely on private landowners voluntarily bringing forward land for 30by30, the government ought to be introducing mandatory nature reporting requirements for England’s largest landowners.

· Indeed, the government’s Land Use Framework, published March 2026, suggests this. It says DEFRA will “explore options for major landowners to report on how climate impacts will affect their land management functions” (under the Adaptation Reporting Power in the Climate Change Act), and also “review other options for major estates to report on their landscape management over the next 12 months, such as exploring the scope of the Agriculture Act 2020.”

· Public reporting is one clear way to ensure accountability by large landowners. It is, after all, the innovation behind the government’s National Estate for Nature Group, set up in 2025 and comprising some of England’s largest landowners, which I’ve written about and praised elsewhere. Today’s 30by30 Delivery Plan leans heavily on what the National Estate for Nature Group are doing, but fails to identify this mandatory public reporting element as the key policy innovation. Simply asking landowners to do nice things doesn’t cut it.

4) Fund a bunch more Landscape Recovery projects

· The most effective and radical part of England’s post-Brexit farm subsidy system is called Landscape Recovery. It is intended to fund big, landscape-scale habitat restoration, involving numerous landowners and farmers collaborating over large areas. It’s proven very popular, with both Rounds 1 and 2 of Landscape Recovery oversubscribed, and with over 50 projects currently making their way through the initial development phase.

· Indeed, DEFRA say that they hope these projects will soon count towards 30by30 – adding another 1.8% of England towards the target.

· So the obvious next thing to do (besides signing off the delivery agreements for the existing 50+ projects) is… finally launch Round 3 of Landscape Recovery. Come on, guys – we’ve been waiting for years for you to announce it!

· DEFRA should also finally publish a map of all the existing Landscape Recovery projects. No such map yet exists in the public domain: I’ve tried my best to map them here. It’s cheeky of DEFRA to include these Landscape Recovery projects in its internal analysis of what might (maybe, possibly) count towards 30by30, but then not release a map showing their boundaries. Without such a map, we can’t see where Landscape Recovery projects overlap with other 30by30 sites (like SSSIs), and check there’s no double-counting going on.

5) Designate lots more SSSIs

· Lastly, and most obviously: if the government were serious about meeting 30by30, it would just legally protect a load more land as Sites of Special Scientific Interest.

· After all, DEFRA’s 30by30 Delivery Plan says that pretty much the only land to currently meet the target – their ‘Gold tier’ – is… SSSIs.

· And yet there is virtually no mention elsewhere in the Delivery Plan of SSSIs. Curious… and yet also, sadly predictable. Because SSSIs are often seen as politically ‘difficult’. That’s because the landowning and shooting lobbies get antsy about their property rights being curtailed – i.e., they don’t get carte blanche to destroy nature when it’s designated as an SSSI.

· Past battles over SSSI designations led the previous Tory government to almost destroy Natural England – with grouse moor-owning ministers seeking to gut its powers after tussles over the new West Penwith SSSI in Cornwall, and efforts to control overgrazing on Dartmoor’s SSSIs. I had hoped this sort of thing would stop when Labour took over. Sadly, under Starmer’s government, we’ve seen both the PM and Chancellor Rachel Reeves attacking newts, bats and Natural England, as supposed blocks on house-building and growth. Faced with this political pressure, Natural England has simply stopped designating new SSSIs in recent years – completely bonkers when we’re just years away from the 30by30 deadline.

· With a new PM taking the reins soon, is it too much to hope for a new approach – one that sees Natural England empowered to create more nature reserves and protect more land as SSSIs?

· Indeed, DEFRA’s more detailed methodology document on how it might meet 30by30 refers to some excellent maps by Natural England called Habitat Network Maps. These take the SSSI series as a starting point (alongside existing Priority Habitats) and then model where it would be best to restore habitat to create connectivity - as the Lawton Review recommended, way back in 2010. Using these maps, DEFRA “identified approximately 12.5% of England with strong ecological suitability for the creation of new habitat.” Clearly, that would take us a lot closer to 30by30.

· So how to do it? Well, the 30by30 Delivery Plan offers no answers (surprise, surprise). But there are two obvious routes. Firstly, spatially-targeted incentives: pay farmers and landowners in those specific areas top dollar to restore habitat networks – such as via a new round of Landscape Recovery funding. And secondly, legally protect these areas for nature by designating more of them as SSSIs.

Unfortunately, today’s 30by30 Delivery Plan doesn’t mention any of these policies. Instead of announcing some exciting new government interventions, it issues a desperate plea naively expecting landowners to voluntarily protect nature. This is the same failed politics of the past forty years – with ministers failing to take public control of the spiralling nature crisis and contracting it out to private landowners who won’t deliver.

When Andy Burnham takes over as PM, I hope he bins this pathetic plan and takes radical action to fix our nature crisis: legally protecting much more land for nature as SSSIs, giving National Parks and the Forestry Commission a legal duty for nature recovery, and funding habitat restoration through many more Landscape Recovery projects. And I hope the nature movement mobilises en masse, to hold the government to account for meeting 30by30. We have four years. Let’s do this.