Memorandum by the Yorkshire Dales National
Park Authority (BIO 29)
1. EFFECTIVENESS
OF UK BIODIVERSITY
POLICIES
1.1 The Biodiversity Action Plan (BAP) process
has gained considerable acceptance across a broad range of disciplines
and is leading to better agency co-operation. It is clear that
the devolvement to local BAPs is ensuring much greater delivery
of the targets than could have been expected if the process had
been purely driven nationally.
1.2 Assessing the effectiveness of the overall
BAP process is, however, difficult since there appears to
have been little co-ordination of monitoring and reporting against
targets (see below). Such monitoring and reporting would be welcome.
1.3 Species that are not currently on UK
BAP list may in future become rare or endangered (witness the
current decline in farmland bird populations). New information
on many species becomes available all the time—how will
the priority list of species and habitats be updated to take account
of changing circumstances?
2. PROGRESS ON
HABITAT AND
SPECIES ACTION
PLANS
2.1 This is currently difficult to assess
as there appears to have been little co-ordination of monitoring
and reporting against targets. There have undoubtedly been some
successes eg new native woodland planting.
3. PRIORITIES
FOR IMPLEMENTATION
3.1 Where local BAP planning is taking place,
widespread consultation with partner agencies is leading to a
prioritisation of action which local agencies from a wide range
of disciplines are very willing to sign up to. The membership
of the Yorkshire Dales National Park Biodiversity Forum which
has endorsed the Yorkshire Dales Local Biodiversity Action Plan—"Nature
in the Dales" is attached as an example of this powerful
partnership approach in action It is difficult to see how
targets will be delivered in areas without local BAPs as it is
unlikely that the same level of consensus and local ownership
of actions will result from national Habitat or Species Groups.
It would seem vital that national groups identify which local
areas they are most likely to work in and develop close working
relationships with local BAP co-ordinators in order to make best
use of local networks. Where local BAPs do not exist they should
be encouraged by agencies responsible for the delivery of national
targets with some urgency. Such encouragement could include the
provision of staff and funding resources.
3.2 A key obstacle to delivering national
targets at local levels is the lack of flexibility in national
agri-environment schemes which prevents MAFF (FRCA) and, to a
lesser extent, English Nature from responding to local differences
with tailored agri-environment support. In the Yorkshire Dales
National Park the majority of actions in the local BAP could be
delivered through appropriate targeted agri-environment support.
Consideration should be given to much greater local flexibility
of these schemes.
4. CO-ORDINATION
BETWEEN NATIONAL
AND LOCAL
LEVELS
4.1 This is currently poor There is
at present no information on whether local plan targets add up
to deliver UK targets. This needs to be assessed with some urgency
and any gaps in UK targets identified and communicated back to
local co-ordinators. Local co-ordinators would welcome such feedback.
4.2 National habitat and species groups
need to identify where they are most likely to target their actions
and proactively contact local co-ordinators to tap into their
local networks.
4.3 The Yorkshire Dales local BAP takes
UK targets as its starting point and cascades these into local
actions. It is important that all local BAPs do this.
4.4 Local BAP co-ordinators also need to
ensure that UK BAP groups and secretariats are kept informed of
local BAP activities so that duplication does not take place and
synergies between different local activities can be recognised
at a national level.
4.5 Where a local BAP is seen to be the
main delivery mechanism for a particular UK HAP or SAP resources
should be made available to the local BAP. An example of where
this approach could be very effective is in the protection and
enhancement of the biodiversity of limestone pavement. 50 per
cent of the UK's pavement is within the Yorkshire Dales National
Park local BAP area and targeting national support to a local
plan in this case would achieve significant biodiversity gains.
5. MONITORING
AND REPORTING
CHANGE
5.1 There is still considerable scope for
agreeing monitoring and reporting methods at a national level.
English Nature have been working hard at developing condition
assessment methods for SACs. The expertise and recording methods
developed for these should be expanded to cover all BAP priority
habitats and made more widely available to ensure standardisation
of biodiversity monitoring.
5.2 There would also seem to be a general
reticence on the part of English Nature and MAFF (FRCA) to put
resources into monitoring. This makes it virtually impossible
for hard pressed local BAP co-ordinators to assess changes in
biodiversity in their areas. There needs to be a definite commitment
from those agencies with significant levels of funding to provide
resources and expertise for biodiversity monitoring. These resources
could be used to good effect locally by involving local communities,
enthusiastic amateurs and volunteers. Volunteers need to be managed
and current resources are not sufficient to enable proper co-ordination
and training of volunteer effort. This is a missed opportunity.
5.3 There also appears to be no mechanism
for updating the list of national priority habitats and species
as a result of national and local monitoring programmes. There
should be some consideration of the BAP review mechanism needs
to be identified.
6. HABITATS AND
BIRDS DIRECTIVE
6.1 The "appropriate assessment"
need under the Habitats Regulations is an important measure in
preventing damage to Natura 2000 sites. It does however, imply
significant resource implications if assessment is to be carried
out properly. In many cases "appropriate assessment"
requires levels of research over and above the resources and capabilities
of individual competent authorities. For example, the need to
carry out detailed experimental research on the impact of disturbance
on breeding upland birds in relation to open access to SPA areas.
6.2 There is also a need to ensure that
competent authorities are made fully aware of their duties and
obligations under the Habitats Regulations. English Nature's guidance
notes are extremely useful but further guidance on the interpretation
of the Regulations should be cascaded to competent authorities
as new case studies become available.
6.3 The impact of the review of extant consents
and permissions that competent authorities are required to do
is a significant undertaking which is currently impossible for
the Yorkshire Dales National Park Authority to comply with given
current staffing and resource levels. Specific resources need
to be provided to local authorities to cope with this requirement
of the legislation.
6.4 It would also be useful if competent
authorities were informed at as early a stage as possible of any
proposed new Natura 2000 sites so that they can assess applications
which may be affected.
6.5 It is unclear when and how the Birds
and Habitats Directives will be amended to include new species
and habitats if new information becomes available and how this
will affect the UK Regulations.
7. PROTECTION
OF BIODIVERSITY
OUTSIDE NATURA
2000 SITES
7.1 The new legislation currently going
through parliament should assist by providing the legislation
to back up wild life protection. Consideration needs to be given
to the resources available to enforcement agencies to police,
investigate and enforce legislative changes. The current staffing
levels and voluntary nature of police wildlife liaison officers
are unlikely to able to enforce such legislative changes.
7.2 In rural areas agri-environment schemes
are likely to remain the main delivery mechanism for biodiversity
change. These must be sufficiently flexible to take account of
local conditions and circumstances and must be designed and resourced
so that they are attractive to landowners and so that all important
habitats are included. Sufficient levels of compliance monitoring
should also be considered to ensure that potential biodiversity
gains are actually being achieved through these schemes.
7.3 There should be a presumption within
the development control system to protect priority habitats and
species identified by both national and local BAPs. This may require
an update of PPG9 and production of guidance materials for planning
authorities particularly where they do not have in-house ecological
expertise.
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