Dame Glenys Stacey's speech at the Forestry Conference 2023

Dame Glenys Stacey, Chair of the OEP, spoke at the Forestry Conference 2023 on Wednesday, 11 October.

Her speech covered the role that forestry and land management has to play in meeting government’s ambitions for the environment, as well as the attributes of an effective environmental improvement plan and the effectiveness of environmental assessment regimes.

The benefits of trees and woodlands in the environment and how policy and law can support landowners - Dame Glenys Stacey

Thank you so much for inviting me to speak to you today, as Chair of the Office for Environmental Protection.

This is my first time speaking at a Forestry Conference and I am so grateful for the opportunity to be here today. 

This is such an interesting time for environmental governance, with the political context generating much discussion and debate. But we must stay focused on the task at hand.

Government remains committed to its ambition to leave the environment in a better state for future generations. It has set statutory targets and refreshed its Environmental Improvement Plan. What is most important now is delivery – how these ambitions are to be delivered. And delivered they must be. Our nature is in crisis. Forestry and land management have such crucial roles to play. These are among the most important branches of the work, if you will forgive me one tree pun. 

It is with that all in mind that I am very much looking forward to hearing from the other speakers and your discussions, and of course, hearing from Minister Harrison. 

I’m fortunate enough to live just down the road from The National Arboretum at Westonbirt, and I visit often. I find it hugely restful, and restorative – and my children and grandchildren really appreciate it as well.  It is a national treasure, in large part because of the sheer majesty of some of those trees.

I hardly need to convince this audience of the benefits of trees. Well managed, healthy trees and woodlands benefit the environment, people and the economy. 

Their environmental benefits alone can include carbon sequestration, biodiversity, flood alleviation, water quality, air quality, soil health. I could go on. Then there are the timber security, green jobs and access benefits too.

As a result, government has high ambitions for trees and woodlands.

They form a key component of the government’s Environmental Improvement Plan (EIP). First in the 25 Year Environment Plan, and now the revised Environmental Improvement Plan published earlier this year.

That is where we, the Office for Environmental Protection, come in.

We were established by the Environment Act with the mission to hold government and other public authorities to account against environmental laws and targets. Our remit includes England and Northern Ireland.

Our role is part of a new approach to environmental governance brought in by the Act which also involves new statutory environmental targets, Environmental Improvement Plans (EIP) and Environmental Principles Policy Statements (EPPS). 

We have four functions – scrutinising EIPs and targets; scrutinising environmental law; advising governments on proposed changes to environmental law; and enforcement. We investigate suspected serious failures to comply with environmental law by public authorities and have a range of powers to enforce compliance. 

That is a very brief description of what we do, which I hope is helpful to those of you who have not yet come across us. Please do see our website for more information on what we do and how we do it. 

Environmental Improvement Plan

The first one of the four functions I just mentioned – assessing and reporting on government’s progress towards delivering its EIP and the statutory environmental targets – is a core part of our role. 

In our first independent report on government’s progress against its 25 Year Environment Plan, published in January, we found that the government was not demonstrably on track to achieve its ambitions. 

Our assessment showed that the current pace and scale of action will not deliver the changes necessary to significantly improve the environment in England. But there is clear opportunity to change course.

Those challenges and opportunities extend to government’s ambitions including for increasing tree canopy and woodland cover, and for increasing the proportion of woodland that is sustainably managed. 

It is pleasing to have seen a recent acceleration in the rate at which trees are being planted and woodlands created, to which I know many of you here will have contributed. But there is still a long way to go to reach the rates required to meet the statutory target to increase woodland and tree canopy cover to 16.5% of land area in England by 2050. Or much more immediately, the government’s commitment to plant 30,000 ha of trees per year across the UK by the end of this Parliament, whenever that might be. The Climate Change Committee, Environmental Audit Committee and National Audit Office have all called for urgent action to get delivery on track. 

This is so important. As government’s Environmental Improvement Plan states, and the Climate Change Committee agree, this is key for the Net Zero Strategy. 

This, and bringing more woodlands into good management, on which – sadly – progress appears limited, are also key to achieving several of the other statutory environmental targets. Many of which require urgent action. Not least to halt the decline in species populations by 2030, and then increase populations by at least 10% to exceed current levels by 2042. 

As the Forestry Commission have told us, woodlands are important for species, supporting more than 250 of the UK’s list of 1150 threatened and declining species. Yet only 9% of woodland and only 36% of woodland Sites of Special Scientific Interest (SSSIs) are in ‘favourable condition’. And growing pressures from climate change, pests, diseases, deer and squirrels make the challenge ever more difficult. Therefore, expansion and improvement of woodlands must be central to any plan to deliver the species target.

To rise to the challenge of delivering all the ambitions described in the Environmental Improvement Plan, we called for better alignment and co-ordination at all levels of Government, local and national, with actions that extended beyond Defra. We also pointed out the need for better targeted and timely data collection and collation, with the goals of the Environmental Improvement Plan in mind, and improved assessment of progress, with a purpose-driven monitoring, evaluation, and learning framework. In short, better planning for effective delivery.

Our analysis for our next EIP monitoring report, which we will publish early next year, is well underway. We will assess progress against individual Environmental Improvement Plan goals, and also intend to conduct an in-depth assessment on the theme of ‘Improving Nature’. 

This reflects the Environmental Improvement Plan 2023 apex target of Thriving Plants and Wildlife. Our work here will include analysis of species abundance and nature recovery targets and the plans in place to deliver them. We will be looking for the barriers to progress, and opportunities to do better. We launched a public call for evidence over the summer and we are now working through the responses. This includes responses from the Forestry Commission and the Woodland Trust, among many others, for which we are very grateful. 

As well as the individual goal areas, the Environmental Improvement Plan 2023 identifies cross-cutting themes such as green finance, making green choices, natural capital, new farming schemes and biodiversity net gain. In analysing the overall picture, we will look at progress from these cross-cutting perspectives and consider goal achievement in the wider societal context, so far as we can.

Our work to date has identified the attributes that in our view make for an effective Environmental Improvement Plan. An EIP should start with a clear vision and translate that into policies, commitments and actions for the whole of government, as well as establishing clear governance arrangements to drive delivery. Delivery plans are key – an overall plan for the EIP supported by detailed plans for each goal area. 

Good data is also important. An effective EIP must make clear use of robust and current data that are aligned to the targets, so this can meaningfully inform the next necessary attribute, which is an evaluation framework that provides proper feedback on actions and progress, so that delivery can be adapted and improved as necessary. 

The reason I set those out here for you, is that we believe this is useful framework that can be applied to work across all areas of the environment and all levels, local, regional and national. 

Reflecting on what this can tell us about your areas of work, I can see some of these attributes in the planning for effective delivery of government’s ambitions for trees and woodlands, that Defra, the Forestry Commission and all their many delivery partners have worked hard to achieve. 

They recognise the need for a systemic approach. One in which seed supply, nursery capacity, biosecurity, land, land managers, investment, skills, science, innovation, technology, markets and regulation are all strengthened and aligned. 

Several of these are themes of this forestry conference today, which is very welcome to see. But there are challenges. Let me touch on three, starting with regulation and oversight regimes.

Regulation and oversight schemes

At the Office for Environmental Protection it is our job to make sure that the laws and regulations in place to protect the environment, which is crucial to our future prosperity and well-being, work well and are being complied with. 

We want to play our part in ensuring the government meets that ambition to leave the environment in a better state for future generations. 

Foresters understand better than most how the choices we make today impact on future generations. Hence the old proverb that ‘the best time to plant a tree was 30 years ago. The second best is now.’

The environment is in crisis. We have to do better, and take the actions now to secure that better future. 

Environmental regulation has a key role to play in this. But it must be good regulation, and well implemented. 

It is vital that the regulations and associated regimes are effective, with clarity over requirements and expectations and proper governance overseeing delivery. We know that delay and complexity can be deeply frustrating, as you plan for land use change. 

With that in mind, we have been looking at Environmental Assessment regimes relating to new developments through our ‘Monitoring’ function. We will be publishing our report next week, but I’d like to give you a sneak preview, as I think the findings will resonate with many here. 

We have a keen interest in these regimes, as government has signalled an intent to change or reform them. There is significant opportunity in doing so, but also risk – as with any such changes. We have looked at the Habitats Regulations Assessment (HRA), Strategic Environmental Assessment (SEA) and Environmental Impact Assessment (EIA) to get a sense of what has been working well and what has not.

We have found that the main barriers to the regimes not being as effective as they might be are in the implementation and delivery within the planning system, rather than in the regulations themselves. There are three main themes that come across in our research: inadequacies in data accessibility; in post decision monitoring, evaluation and reporting; and in public authorities’ access to necessary expertise. 

We don’t just see these themes here, the same types of issues around implementation crop up time and time again in our work. I suspect you face similar issues in forestry. And you can no doubt see how they relate to the attributes we have identified for effective implementation of EIPs. 

Thinking then about the wider theme of your event, The Next Generation, Securing our Future, I want to pick up in particular on the public authorities’ lack of access to necessary expertise. 

There is a question here, a challenge indeed, for all of us here. How do we ensure that we attract, train and retain the skilled and dedicated people we need to effectively deliver environmental protection and improvement?

We here all know how rewarding it can be working in this sector – although it is not without its challenges! And I am regularly impressed by the knowledge, skills and commitment I see from people of all ages and experience across the sector – there is genuine talent out there, and, I’m sure, here today.

But something isn’t working. We repeatedly come across skills shortages, gaps in knowledge and experience, and often where it could make a real difference.

Do we have the right qualifications and career paths to attract young people into the sector? How do we ensure people stay in the roles where their skills and can be of most use and benefit? How do we ensure those roles exist and are supported? 

I understand that many of you have been seeking answers to similar questions for forestry and land management.

We at the OEP don’t have the answers. We are trying to do our bit through presenting evidence of the issue and its impact to help drive the case for change. And, closer to home, through apprenticeships and mentoring programmes. 

I am so interested to hear your discussions and to learn from all of you. It is such an important aspect of securing the future for our environment. 

Biodiversity Net Gain

Let me turn now to Biodiversity Net Gain.

During the consultation we called for a strong system of governance to oversee implementation, monitoring, reporting and enforcement, and for adequate resourcing and expertise to be put in place, covering both initial assessments of applications and long-term oversight of BNG.

Those recurring implementation themes again. 

We were disappointed to see the recent announcement of the delay to the introduction of these requirements. The need for change is urgent – all delays are unwelcome. We can only hope that the additional time is used productively to put the right measures in place to ensure the scheme is effective and meets its aims.

We would certainly expect to see meaningful engagement with Natural England on any next steps, and appropriate regard to the Environmental Principles Policy Statement requirements, which come into effect on 1 November. 

Last but by no means least, a word about ELMS. I know that land managers want certainty about ELMS. Especially those considering creating new woodlands or improving existing ones, and how to cover the high capital costs with establishment, and the ongoing costs of management. ELMS has great potential in furthering government’s ambitions for the environment. It does need to work well for trees and woodland, linked as they are to so many of government’s wider ambitions for the environment. We will watch with interest as the England Woodland Creation Offer becomes part of the ELMS Local Nature Recovery scheme from 2025. Our own work on ELMS is only just beginning.


To conclude, let me return to the main theme of your event – Securing the Future. The Government’s ambition remains to leave the environment in a better condition for future generations. And it so heartening to see you so focused on the future in the discussions here today.

For our part, we see that having effective environmental laws that are well designed and well implemented will provide the healthy roots from which that future will grow and flourish. (Apologies for a second – but final - tree pun).

Thank you for listening, and for inviting me to your conference. I am very much looking forward to hearing from all of you. 

Dame Glenys Stacey