Speak Up for Nature: Respond to the Nature Recovery Strategy Consultation

Yes. 

The five strategic objectives of the draft NRS are broadly sensible, with an appropriate focus on protecting nature, accelerating restoration, and embedding biodiversity considerations across government. Achieving these aims will depend on reducing the major pressures on biodiversity, expanding nature‑friendly farming, and dramatically improving data and monitoring so that progress on species and habitats can be meaningfully assessed. 

However, the actions and targets proposed in the draft NRS fall far short of what will be required to deliver these objectives. Many lack clear, measurable targets, as well as clarity on delivery or funding, and focus heavily on producing new plans or reviewing options rather than committing to concrete improvements on the ground. Without a significant strengthening of ambition and specificity, the Strategic Objectives will remain unachievable. 

No. 

The targets and actions in this section will not achieve Strategic Objective 1 (SO1). The majority of them are to create more plans and strategies. These will be important but will not guarantee real action will be taken to recover nature. Most of the proposed targets and actions will not themselves have a direct impact on protecting nature or accelerating restoration. To achieve SO1, the strategy must include time‑bound, funded delivery measures. 

Yes. 

As the draft NRS itself notes, protected sites are the cornerstone of nature protection and recovery. There is a critical opportunity here to commit to further designations - action that would lock in long‑term benefits for nature, climate resilience and communities - but the current proposals are not sufficiently SMART to deliver this.  The extension of the Antrim Hills SPA (geographically and to include Curlew as a feature) and the creation of a Lower Lough Erne SPA (Curlew as a feature) must be included as SMART targets within the NRS. These are now required by the UK Third SPA Review and would constitute a clear commitment to protecting nature in NI. Developing a delivery plan for protected sites is important, but it is not a sufficiently SMART target and will not in itself result in designations. The target must be what it is really being aimed at, namely more land designated for nature. This must involve a clear target for management plans and measures to be undertaken to ensure current and future protected sites are meaningfully protected for nature. 

There is discussion of other effective area-based conservation measures (OECMs) within the draft NRS. While important for achieving the 30by30 target these must be developed carefully. A framework for OECMs is crucial and it must uphold the standards set by the International Union for the Conservation of Nature guidelines on OECMs. A SMART target for the development at pace of such a framework should be set within the NRS to ensure it is developed in a timely fashion while also being rigorous. The sooner this exists the sooner it can be scrutinised.

Yes. 

The ambition of targets and actions must be significantly increased to achieve SO1. The Biodiversity Strategy 2015-20 lacked ambition and did not result in an improved situation for nature. Until the NRS, no further strategy was forthcoming, and DAERA has not significantly advanced nature recovery through its policies. The NRS in its current state risks being a lost opportunity at a crucial juncture for nature in NI. Ambition must be urgently and significantly increased and the NRS made sufficiently SMART to deliver this. 

No. 

The proposed actions under SO2 are too broad and lack the SMART detail needed to ensure real reductions in pressures on biodiversity. Most actions focus on publishing or consulting on plans rather than delivering measurable change, and several simply restate existing commitments. While targets for plastic pollution, air quality and invasive species are important, they will not address the most significant pressures on biodiversity. 

Crucially, the proposed actions do not reflect the main drivers of biodiversity loss in Northern Ireland identified by the OEP), particularly nutrient pollution and land‑use impacts. The absence of a specific target for reducing nutrient runoff, especially phosphorus entering waterways, represents a major gap. Land‑use change and habitat deterioration - significant pressures on biodiversity - should also be recognised within SO2. Without addressing these core issues, the proposed actions will not deliver the reduction in pressures required to achieve nature recovery.  

Yes. 

A SMART target for reducing nutrient pollution would be appropriate within the NRS. This could then be tied to the development of the Nutrients Action Programme as one of the principle means to achieving this target. 

For certain priority bird species there is a consistent threat from predation. There is no discussion of predator control within the NRS. A SMART target focused on dedicated funding or other support for predator control on key breeding sites would be appropriate within SO2. 

Yes. 

Some of the new targets and actions under SO2 appear to recycle commitments made elsewhere and have been added to the NRS with limited relevance. For example, a Clean Air Strategy has long been expected from DAERA in response to sustained calls from the health and environmental sectors, independent of the NRS process. While cleaner air is not irrelevant to biodiversity, incorporating an already‑anticipated commitment does not advance the strategy and signals a lack of new, meaningful ambition. 

No. 

The proposed actions under SO3 will not deliver genuinely sustainable use of biodiversity. Nature‑friendly farming remains at very low uptake in Northern Ireland, and without a major increase in scale and funding, agriculture will continue to drive habitat degradation and nutrient pollution. The commitment to roll out further Farming with Nature strands is already an existing policy ambition, and without clear, SMART detail it adds nothing tangible and meaningful. The same applies to Fisheries Management Plans, which are essential but lack any specificity that would ensure measurable improvements. 

The inclusion of an action to merely “explore and review options” for biodiversity net gain underscores the lack of ambition within SO3. Such vague wording could be satisfied without delivering any real change, which is wholly inadequate given the deteriorating condition of habitats and chronic underfunding for restoration. Without specific, measurable commitments on both farming and fisheries, the actions under SO3 fall far short of what is required to achieve sustainable use of biodiversity. 

Yes. 

SMART targets for both the roll out of Farming with Nature packages and the management of fisheries should be included within SO3. These must incorporate budget commitments if they are to have any impact. 

Yes. 

The targets and actions under SO3 are particularly underdeveloped in the context of the draft NRS. Overall, SO3 should outline a clear pathway towards widespread adoption of nature‑friendly farming and sustainable fisheries, underpinned by strong regulatory standards and adequately funded schemes. Without such detail, the actions listed under SO3 fall well short of what is required to secure the sustainable use of biodiversity across Northern Ireland. 

No. 

The actions proposed under SO4 are not ambitious enough to embed biodiversity across government and society. Behaviour‑change campaigns and voluntary business initiatives cannot substitute for structural integration of biodiversity into policy‑making, procurement, planning, and economic decisions. The delays in implementing the Environmental Principles Policy Statement further undermine the Strategy’s capacity to mainstream nature. Several actions, such as developing future funding mechanisms or frameworks for restoration targets, sit awkwardly within SO4, lacking clear relevance to valuing and mainstreaming nature specifically. 

The actions also lack SMART detail. Targets to simply “encourage” businesses to take up a biodiversity charter mark or to consider legislative routes for nature restoration offer no certainty of delivery. The sequencing of actions on reporting the biodiversity duty and setting restoration targets is also unclear, with steps depending on outcomes that have not yet been secured. Overall, SO4 requires clearer, more targeted commitments if it is to drive genuine mainstreaming of biodiversity across government and society.  

No. 

The targets and actions under SO4 should be trimmed down and SMART targets added to be made more focused and manageable. 

No. 

No. 

The proposed actions under SO4 will not deliver strong, integrated evidence and knowledge. Data gaps in NI are well‑documented, including inadequate monitoring of habitat condition, species abundance, and ecosystem functioning. The draft NRS fails to commit to the scale of investment and reform required to address these gaps. Without a fully costed, SMART roadmap for long‑term monitoring and evidence collection, SO5 cannot succeed in underpinning nature recovery. 

Yes. 

The NRS should commit to funding long‑term ecological monitoring, supporting citizen science programmes, and integrating data from landowners, NGOs, and statutory bodies into a unified evidence framework. Data sets should be publicly available for the purpose of NGO research and practical work on habitats and species, as well as for public scrutiny. 

Yes. 

SO5 must acknowledge that progress on biodiversity reporting in NI has been historically slow, fragmented, and under‑resourced. The absence of comprehensive biodiversity indicators and regular protected site condition assessments has significantly hindered progress. The NRS should therefore commit to annual publication of all biodiversity indicators, a statutory duty to monitor protected sites, and partnerships with academic institutions to ensure methodological rigour. 

Yes. 

Several existing targets relevant to delivering SO1–SO5 have been omitted. These include legal requirements to progress SPA designations, and obligations under the (draft) Climate Action Plan to deliver nature‑based solutions. Integrating these with an outlining of resourcing and SMART targets into the NRS is essential to provide a coherent, cross‑government approach to nature recovery in Northern Ireland.