MEMORANDUM BY PLANTLIFE (BIO 20)
1. INTRODUCTION
TO PLANTLIFE
AND BACK
FROM THE
BRINK
Plantlife is Britain's only national membership
charity dedicated exclusively to conserving all forms of plant
life in their natural habitats; the nation's champions of wild
plants. It has 12,000 members and owns 22 nature reserves with
a total land holding of 3,900 acres. Plantlife is "Lead Partner"
for 77 species under the Government's Biodiversity Initiative.
Conservation of these is delivered through a recovery programme
called Back from the Brink, which implements Species Action
Plans through survey, research, practical action and advice. Plantlife
involves its members as volunteers in delivering this work, at
present over 200 people contribute towards Back from the Brink
in this way. Plantlife also acts as the secretarial for Planta
Europa, the European network of organisations and individuals
interested in plant conservation and botanical research.
Plantlife welcomes the opportunity to contribute
evidence to this Inquiry and believes it is uniquely placed to
review Government's progress in implementing policies and plans
for plant biodiversity. This evidence will be broadly divided
into four parts:
— The status of our wild plants and
the threats they are facing;
— Progress in implementation of Biodiversity
Action Plans for priority species and habitats;
— Development of UK Biodiversity Policies;
— Recommendations for future action.
2. CONTEXT
2.1 Status of Our Flora
At least 107 species of plant (including flowering
plants, ferns, lichens, mosses and fungi) have gone extinct this
century. Their habitats have been devastated over the past 50
years and we have lost 98 per cent of wild flower meadows; 75
per cent of open heaths; 96 per cent of open peat bogs; and 190,000
kilometres of hedgerows.
The Biodiversity Action Plan, Government's imaginative
response to the Rio Convention, lists 168 plant species threatened
with extinction or severe decline. Many more are known to be vanishing
from large areas of the countryside. For example wild chamomile
has been lost from 23 counties and the native fritillary is now
found in only a quarter of its former range. Recently published
county floras indicate that we are losing roughly 10 species of
wild flower in each county every 10 years, with a higher extinction
rate for mosses and lichens. At a parish level, the extinction
rate is thought to be higher still.
2.2 Threats Facing Wild Plants
The published Action Plans for plants and their
habitats identify the major threats faced by the British flora.
Analysis of these reveals that plants are vulnerable to a range
of different impacts. [40]
For example:
— agricultural intensification is a
threat to over half of the priority flowering plants and nearly
80 per cent of important plant habitats;
— habitat destruction threatens over
two thirds of these habitats;
— air pollution and eutrophication
are particular problems for lower plants;
— climate change is identified as a
threat to over 50 per cent of important plant habitats;
— non-native invasive species are threatening
the survival of a range of plants, but particularly our native
aquatic flora;
— water pollution and abstraction threaten
nearly half of the priority habitats for plants.
In developing the UK Biodiversity Action Plan,
Government sought to address these threats by targeting actions
at each species and habitat; but it also recognised the need for
a policy framework which would implement cross-cutting reforms
for wildlife. Key elements of this framework for wild plants are:
— reversing agricultural intensification;
— protecting and managing the places
where the most threatened plants grow;
— combating environmental pollution;
and
— controlling the release of non-native
invasive species.
3. SUCCESSES
AND CONSTRAINTS
OF THE
BIODIVERSITY ACTION
PLAN PROCESS
FOR PRIORITY
SPECIES AND
HABITATS
3.1 Progress with Species Action Plans
Plantlife believes that significant progress
has been made in implementing plans for plants. Plantlife is Lead
Partner for nine Tranche One species action plans (published in
1995). Out of a total of 117 actions in these plans, significant
progress has been made on 92 (79 per cent). We have evidence that
the decline of four of these species has been halted or reversed;
further information is required about the remaining five before
trends can be assessed. Of six Tranche Two species which are within
Plantlife's Back from the Brink programme, over 70 per
cent of actions have been progressed. One species is still in
decline, two have been stabilised, one shows significant signs
of recovery and two await further information.
Plantlife attributes this encouraging start
to increased resources made available through species recovery
programmes; commitment by a range of partners in the voluntary
sector and Government; and the amenability of species to site-targeted
plans. It is confident that similar progress can be made in implementing
the remaining plans for plants, the majority of which were published
in 1999.
However, there are still significant obstacles
to progress, many of which require action to be taken through
a habitat plan or through a broader policy framework. An analysis
of constraints using JNCC Lead Partner forms for 27 plant species
shows the following repeatedly identified blockages. These must
be addressed through the relevant parts of Government policy and
legislation.
| Blockage | % of forms in which this was cited
|
| Information and research inadequate | 78
|
| Agri-environment schemes and agricultural policies inadequate
| 41 |
| Species or habitat protection inadequate |
30 |
| Management on protected areas inadequate |
22 |
| Water pollution | 19 |
| Recreation impacts | 19 |
| Awareness and advice provision inadequate |
19 |
| Management of areas of abandoned land inadequate
| 15 |
3.2 Progress with Habitat Action Plans
Plantlife is concerned that progress in implementing habitat
action plans is stalled. Analysis of the reporting forms for priority
habitats suggests that five out of 14 Tranche One habitats are
"showing signs of recovery". This is welcome news, particularly
where it can be supported by evidence of change on the ground
(for example the restoration of native pine woods and reed beds).
However, there is a danger that any progress which has been made
will be jeopardised by delays in developing appropriate steering
group mechanisms. Whilst the majority of Tranche One habitats
do have a steering group, recent discussions with the chairpersons
of groups revealed that action was "on hold" pending
the implementation of a new structure for habitat plans.
In 1998 English Nature proposed the development of "over-arching
groups" for habitats. The intention was that these should
add to rather than replace individual habitat groups. It was felt
that senior representation from the voluntary and statutory sectors
on overarching groups would allow the delivery of policy changes
and additional resources, whilst individual work programmes would
remain the responsibility of single habitat or issue-based working
groups. Sadly, progress in implementing this model has been slow.
Plantlife is concerned that it may be abandoned in favour of overarching
groups which would replace single habitat groups but have no increased
resources or political influence. Recent correspondence with CCW
regarding the framework of the proposed over-arching grasslands
group confirms these worries.
In addition to these immediate structural problems, JNCC
reporting forms have helped to identify the key policy constraints
which are blocking progress on habitat action plans. Blockages
to Progress for 14 Tranche One Priority Habitats are shown below:
| Blockage | % of forms in which this was cited
|
| Agricultural and policy agri-environment measures
| 64 |
| Information and research inadequate | 64
|
| Re-creation and recovery schemes inadequate
| 43 |
| Lack of commitment to delivering BAP targets
| 43 |
| Water pollution | 36 |
| Management and enforcement on protected areas inadequate
| 29 |
| Protection of habitat inadequate | 29
|
To ensure that real progress is made in the next five years,
appropriate structures for management of the plans need to be
put in place and a policy framework adopted to tackle these blockages.
In particular Plantlife suggests that an innovative approach to
habitat recovery needs to be established to help achieve recreation
targets.
3.3 Integration of species and habitat work
Plantlife is concerned about the lack of integration of species
and habitat groups. Species which occur on only a tiny number
of sites can be effectively supported through action targeted
at individual populations. Widespread species, however, are dependent
on habitat restoration and management being delivered through
habitat action plans to achieve BAP targets. Some good practice
in integrating species and habitat needs is being developed, for
example by integration of the Reedbeds and Bittern Group. This
needs to be extended, particularly when developing generic management
guidance and when targeting funding at sites. Plantlife believes
sites supporting BAP species or sites suitable for their restoration
should be given priority.
3.4 Integration of national and local Biodiversity Action
Plans
Integration problems are also being experienced between national
and local tiers of BAP. Many local BAPs were developed before
all priority species and habitat action plans were published,
and do not always reflect national priorities. There are also
difficulties in ensuring that process and biological information
flows smoothly between Lead Partners and Agencies and local BAP
practitioners. It is imperative that communication is improved,
as many elements of BAP can only be delivered through the local
process. Further resources should be invested in information exchange
systems, including all elements of the National Biodiversity Network.
In addition, the appointment of staff dedicated to maintaining
up-to-date information about the local BAP process and liaising
between local and national BAP partners would ease current problems.
Concern has been expressed by many local BAP practitioners
that the lack of a statutory obligation on local authorities to
meet BSP commitments weakens their position and puts in jeopardy
work which is already going forward at a local level. Legal underpinning
of the BAP process would help to address this problem.
3.5 Reporting process
During 1999 Lead Partners and Agencies were required to complete
a reporting form for each species and habitat action plan. Whilst
Plantlife enthusiastically supports the need for a reporting mechanism
to test implementation and effectiveness of the BAP, the process
itself was excessively time-consuming for many small and middle-sized
Lead Partners. It is important that the information gained from
the reporting round should be made fully available as quickly
as possible. In addition, a reporting process should be developed
which is less burdensome but still captures key indicators of
performance at a process and biological level. Since biological
progress is the ultimate measure of the success of the plan, it
is imperative that structures are put in place to gather the necessary
monitoring data about species and habitats. This requires investment
in both field recording and information processing through the
National Biodiversity Network.
4. GOVERNMENT POLICY
AND LEGISLATION
Plantlife's analysis of the threats facing Britain's wild
plants and of the constraints to implementing species and habitat
action plans enables it to identify the following key issues for
consideration by this inquiry:
— reversing impacts of agricultural intensification;
— preventing habitat destruction and neglect;
— addressing environmental pollution, including
water pollution;
— combating the effects of non-native species;
— provision of information and research.
These will be considered within the current legislative and
policy frameworks.
4.1 Legislative framework
Plantlife has welcomed the Countryside and Rights of Way
Bill for England and Wales (the CROW Bill) and looks to Scotland
and Northern Ireland to bring forward complementary legislation
as soon as possible. This represents a once in 20 year opportunity
to improve protection of biodiversity. We must ensure that the
resulting legal framework is strong enough to enable us to manage
the effects of a changing climate and shifting public aspirations.
The following remarks relate specifically to the CROW Bill but
the principles can broadly be applied to the whole of the UK.
Plantlife applauds Government for introducing a new package
of protection and management measures for our most important wildlife
sites (Sites of Special Scientific Interest) in England and Wales.
This will go some way towards addressing the problems of habitat
destruction and neglect faced by wild plants. In Scotland, we
await with some concern the outcome of the recent "People
and Nature" consultation on SSSIs which may have implied
a significant weakening in the protection of SSSIs. Also, Plantlife
estimates that one quarter of all sites for priority plant species
are outside SSSIs. Part I of the Wildlife and Countryside Act(
WCA) is currently woefully inadequate to protect plants in the
wider countryside.
We would welcome information as to how the next quinquennial
review of the Schedules of the Wildlife and Countryside Act will
operate in a newly devolved Great Britain.
4.1.1 Protection and management outside SSSIs
Many sites for threatened plants are outside protected areas.
Some, which are especially vulnerable to habitat damage, are also
badly represented in the SSSI series; for example only one in
four sites for Cotswold pennycress Thlaspi perfoliatum
is within an SSSI. The survival of this species depends on habitat
protection and management in the wider countryside. A related
issue arises with respect of internationally important species
such as shore dock Rumex rupestris and floating water-plantain
Luronium natans. There is currently no appropriate mechanism
to implement Article 10 of the Habitats and Species Directive
(which states that "Member States shall . . . encourage the
management of features of the landscape which are of major importance
to fauna and flora") outside of the existing protected areas
framework.
The law must address protection and management of priority
species outside SSSIs/SACs—at the moment both the CROW Bill
and the Conservation (Natural Habitats &c) Regulations 1994
(the Habitat Regulations) neglect this issue. Plantlife supports
the recommendation made by the Joint Nature Conservation Committee
to DETR in its advice on species legislation (JNCC, 2000) which
suggests that Statutory Conservation Agencies should be given
the power to enter into management agreements with owners/occupiers
outside SSSIs/SACs. This must be backed up by appropriate financial
support.
4.1.2 Invasive species
Many wetland plants and habitats are threatened by invasive
alien species. For example, starfruit Damasonium alisma,
a species of pond margins which was once relatively common in
southern England, is threatened with extinction on five of its
remaining nine sites by the growth of Crassula helmsii
(Australian swamp stonecrop or New Zealand Pigmyweed). Crassula
helmsii was nominated for inclusion on Schedule 9 of the WCA
in 1995, but no action was taken. The list of plants on Schedule
9 has not been updated since 1992.
Tougher penalties, as proposed in the CROW Bill, for the
illegal release of non-native invasive species are welcome, but
will do little unless other parts of the law are changed. There
have to date been no convictions for illegal release of Schedule
9 plants into the wild. It is widely acknowledged that this is
because Section 14 of the WCA is itself flawed. At the moment
the law can only respond if a plant is shown to cause environmental
problems—a case of shutting the door after the horse has
bolted. JNCC supports Plantlife's view that the law must be changed
to reflect a more precautionary approach towards species which
are likely to cause environmental damage. Crucially both JNCC
and Plantlife believe that the sale of problem species should
also be banned.
One issue which JNCC neglects is the issue of control. At
present there is no mechanism to control problem species once
they are out in the wild. This contravenes the Convention on Biological
Diversity 1992 which says that "each contracting party should,
as far as possible, and as appropriate: prevent the introduction
of, control and eradicate alien species". A centrally co-ordinated
eradication programme should be established to address this. This
issue also needs to be addressed by the Scottish Parliament.
4.1.3 Provision of a legal basis for the biodiversity action
plan
A significant constraint to progress has been the unwillingness
of various parts of central and local government to engage with
BAP and fulfil their responsibilities. A legal underpinning of
the BAP process would ensure that any future Government could
not ignore commitments to biodiversity made by previous governments.
In December 1999 the Countryside Council for Wales admitted that
they could only deliver half their BAP commitments with their
current resources. If all public bodies had a duty to further
the objectives of species and habitat action plans, this situation
would be less likely to emerge. At present public bodies can point
to their duty to fund other, statutory obligations as the reason
for their failure to deliver BAP. As long as this situation continues,
the conservation of biodiversity will be an optional extra rather
than a requirement of Government. This issue also needs to be
addressed by the Scottish Parliament.
4.2 POLICY FRAMEWORK
4.2.1 Agriculture policy
Intensification of farming practices over the past 50 years
has been disastrous for Britain's wild plants. The main driving
force behind is the production subsidies of the Common Agricultural
Policy (CAP). Agenda 2000 reforms to the CAP now offer significant
opportunities for the Government to shift the emphasis of farming
support to promote the role of farming in environmental protection
and biodiversity conservation. Plantlife believes Government should
attach environmental conditions to agricultural support payments
(cross-compliance). This introduction of simple cross-compliance
measures could deliver significant environmental benefits and
would be fairer to farmers who are already farming in an environmentally
sympathetic manner.
Agri-environment schemes have recently received a welcome
boost in England and Wales and should now be better able to cater
for the needs of BAP species. We await a similar announcement
in Scotland. Reliable data on plant distributions should help
proper targeting of resources. Plantlife urges that Government
continue to work for further modulation so that 20 per cent of
the Common Agricultural Policy budget is directed towards incentives
for positive management for nature conservation and other rural
development measures.
Certain arable plants are particularly at risk from changes
to crop rotations and changes in the timing of agricultural operations.
This has led Plantlife to adopt a precautionary approach to the
release of genetically modified organisms. Plantlife is concerned
that the use of GMOs may cause a further shift away from rotations,
or from spring to autumn sowing dates. This could spell disaster
for arable plants, such as cornflower Centaurea cyanus
and pheasant's eye Adonis annua, which are already suffering
major declines. Plantlife will not support commercial release
of GMOs until field trials have shown that they, or the changes
in agricultural practices that will result, pose no threat to
the environment.
4.2.2 Water Resource Management
Many species and habitats rely on appropriate management
of our water resources for their survival. Creeping eutrophication
is having a particularly damaging effect on aquatic ecosystems
and plant communities, not just in lakes but in ditches, streams
and ponds. Responsibility for the protection of all in-land aquatic
habitats should lie with the Environment Agency, who should be
encouraged to integrate biodiversity targets into all areas of
their work. Water companies must be obliged to manage the UK water
resource in a manner which is compatible with targets laid down
in the UK BAP.
4.2.3 Planning Policy
Since its establishment, the planning system has played a
valuable role in protecting the countryside. Yet weaknesses in
the system allow environmentally damaging activity to take place.
Plantlife believes that the system should ensure the long-term
protection of our wild plant heritage; promote a new model of
development which integrates economic, social and environmental
considerations; and be objective-led. Specifically, we believe
that the current planning policy guidance for nature conservation
is in urgent need of revision to complement measures included
in the CROW Bill and future legislation in Scotland and Northern
Ireland. This guidance should embrace the precautionary approach
and explain what it means in practice; include a presumption against
damaging development on our most important wildlife sites; and
clarify the role of the planning system in the delivery of BAP
targets.
4.2.4 Research and information provision
Lack of sufficient information about the distribution of
priority species and habitats is one of the major obstacles to
delivery of the UK BAP. Yet at present there is inadequate commitment
to the long-term funding of the National Biodiversity Network.
Without this it will be impossible to measure the biological impact
of BAP, rendering the target-led approach unworkable and squandering
the resources which have so far been invested in the process.
This must be tackled by adequate provision of resources through
DETR to JNCC.
Similarly, gaps in our knowledge of the ecology of habitats
and species are seriously impeding the delivery of BAP. Plantlife
suggests that this can most effectively be addressed by ensuring
that the Natural Environment Research Council (NERC) and through
it the Universities have a programme specifically dedicated to
research on BAP species and habitats. This should enable research
on individual species as well as cross-cutting themes.
The Biodiversity Action Plan is our conservation agenda for
today. Plantlife believes it is essential that we identify and
respond to the conservation agenda of tomorrow. A credible system
of monitoring our more common plants therefore needs to be developed
which we can use to monitor the effects of climate change, agricultural
intensification, GM crops or any other factor that might affect
species abundance. A pilot project has been launched this summer
and this needs continued support.
5. RECOMMENDATIONS FOR
FUTURE ACTION
Plantlife's key recommendations, distilled from the above
evidence, are as follows.
Process:
Immediately implement the EN model for over-arching habitat
action plan steering groups.
Develop guidance on the areas of overlap between species
and habitat action plans.
Create an adequate database of local biodiversity action
plans and commit staff resources to facilitating national and
local links.
Legislation (recommendations for each relevant devolved administration):
Introduce new measures to protect and manage habitats of
threatened species outside SSSIs.
Strengthen measures to protect the environment from impacts
of invasive plant species.
Legally underpin the BAP process and introduce a duty on
all public bodies, including local authorities, to further the
objectives of published species and habitat action plans.
Policy (recommendations for each relevant devolved administration):
Support rural development initiatives with at least 20 per
cent of the agriculture budget.
Introduce environmental conditions on all CAP payments.
Maintain moratorium on commercial growth of GMOs until trials
have shown they pose no threat to the environment.
Revise planning policy guidance to strengthen the role of
the planning system in delivering BAP targets.
Fund and implement a Habitat Recovery Programme.
Provide the Natural Environment and Research Council (NERC)
with a dedicated budget for BAP priority species and habitats.
Immediately provide adequate resourcing for NBN.
Develop a credible annual Common Plants Survey.
April 2000
40
Based on analysis of 168 plant species action plans and 34 habitat
action plans for priority habitats known to be important for plants. Back
| 
