MEMORANDUM BY THE BUTTERFLY CONSERVATION
(BIO 28)
SUMMARY
The conservation of biological diversity through
an objective led, planned approach is an exciting development
in nature conservation. The publication of biodiversity action
plans (BAPs) for priority habitats and species is a welcome first
step. Even in the short time since publication of the first plans
progress has been made in turning these plans into action, and
for invertebrate conservation in particular there has been a significant
increase in profile. However, the process is still in its infancy
and much greater effort and resources are still required to effectively
deliver the objectives of the plans.
Butterfly Conservation welcomes the opportunity
to comment on the biodiversity process and recommends:
— consideration is given to a mechanism
to ensure a regular review of the priority habitats and species
is undertaken and core support for the National Biodiversity Network
is essential to enable the co-ordination of the data necessary
for such a review;
— lead agencies need to ensure staff
are allocated sufficient time and resources to co-ordinate the
steering groups, which should be seen as a key mechanism for the
delivery of habitat conservation in the UK;
— the DETR Biodiversity Secretariat
should clarify lines of responsibility and develop a mechanism
for dealing with any lack of commitment to the process;
— the UK Biodiversity Action Plan process
should be given legal backing. Ministers and all public bodies,
including local authorities, should be given a duty to further
the objectives of published Species and Habitat Action Plans;
— stronger measures are needed to protect
and enhance the management of land, outside notified wildlife
sites, that supports priority species;
— the UK Government should press for
at least 25 per cent of the EU agriculture budget to go to supporting
the Rural Development Regulation;
— the UKBG should review the reporting
process and ensure the arrangements for the next round of reporting
are prepared well in advance of 2002. This process should also
give an opportunity for Local BAP initiatives to report.
1. INTRODUCTION
1.1 Butterfly Conservation is pleased to
submit evidence to the Environment Sub-committee on the Environment,
Transport and Regional Affairs Committee.
1.2 Butterfly Conservation is Europe's largest
invertebrate conservation charity with a membership of over 10,000
and an active volunteer network of local branches throughout the
UK. As a member of the Biodiversity Challenge Group we have played
a full role in developing and implementing the Biodiversity process
in the UK since the signing of the Convention on Biological Diversity.
1.3 Butterfly Conservation is "lead
partner" for 45 priority butterflies and moths. BCs lead
partner work has been driven through two major programmes of work
the "Action for Butterflies Project" jointly funded
by English Nature, Countryside Council for Wales, Scottish Natural
Heritage, World Wide Fund for Nature and Butterfly Conservation
since 1994 and the "Action for Moths Project" funded
by English Nature and Butterfly Conservation since 1999. These
projects work nationally to turn the Species Plans into conservation
action at the national policy and research level, and locally
through our volunteers and local partner organisations. We believe
that our experience through these projects ensures we are uniquely
placed to comment on the Biodiversity process from both a local
and national perspective.
2. THE STATUS
OF OUR
BUTTERFLIES AND
MOTHS
2.1 Like all Biodiversity in the UK, butterflies
and moths (and other invertebrates) have suffered large-scale
losses this century. For the butterflies the losses are well known
and alarming, often being at a scale 10 times greater than other
less sensitive taxa[60].
Five species (8 per cent of total fauna) have become extinct,
14 species (24 per cent of total fauna) have declined by over
50 per cent, and 15 species (25 per cent of total fauna) have
declined by between 20 per cent and 50 per cent. Of the remaining
25 species that are stable or even expanding five species have
experienced major declines within their range[61].
While a review of the evidence of similar declines for the moths
nationally is not available, several local studies indicate that
the picture is similar, for example a recent study in the New
Forest has demonstrated that 50 per cent of the scarce and threatened
moths may now be extinct[62].
The need for concerted action to conserve our butterflies and
moths has never been greater.
2.2 The major threats to butterflies and
moths is through habitat loss (through development, agricultural
intensification and forestry) and habitat change. Butterflies
are particularly sensitive to changing management of sites and
make good indicators of such changes in habitat quality. Abandonment
of semi natural habitats, or intensification is thus of particular
concern for the butterflies and moths. [63]
[64]
2.3 Butterfly Conservation believes that
the UK approach to biodiversity conservation, with its focus on
biological objectives and a planned, partnership approach to achieve
these ends is thus both practical and timely.
3. PROGRESS ON
THE IMPLEMENTATION
OF SPECIES
PLANS
3.1 The publication, by Government, of 436
species and habitat action plans represents real progress in the
development of a planned, targeted, approach to the conservation
of the UK's biodiversity. However, these plans need to be seen
to be delivering conservation action and hence ensuring the biological
targets in the plans are being met
3.2 In the experience of Butterfly Conservation
significant progress has been made with many of the actions in
the majority of species action plans through increased funding
through Species Recovery programmes and some corporate sponsorship.
This has often been either for localised species or on the research
and survey aspects of the plans. For example the continuing progress
with the re-introduction of the Large Blue, or the major increase
in our knowledge of the distribution and management of the Pearl-bordered,
Heath and Marsh Fritillaries has been made possible thanks to
the financial support of the Country Agencies and corporate sponsors
like ICI.
3.3 Significantly less progress has been
achieved on those species that are widespread but declining and
which require landscape scale policy changes such as the Marsh
Fritillary. While the important role Agri-environment schemes
can play in the conservation of the UK's biodiversity has been
recognised, the welcome increase in the resources going into these
schemes is still too limited to address the serious decline of
this and other species.
4. MAINTAINING
THE MOMENTUM
4.1 As indicated previously, Butterfly Conservation
believes that the biodiversity process should be seen as a key
mechanism for ensuring that the UK's biodiversity is maintained
and enhanced (2.3 above). A key component of this process is the
review of actions and priorities. We have recent good evidence
that 18 species of butterfly have shown major declines including
eight further species that should qualify for priority status[65].
These are the Wood White, Large Heath, Duke of Burgundy, Dingy
Skipper, Brown Hairstreak, Dark Green Fritillary, Small Pearl-bordered
Fritillary, Grayling and Grizzled Skipper.
We believe that some consideration needs to
be given to how the priority species and habitats are reviewed
regularly to ensure that the process is addressing current priorities
in conservation.
4.2 The lack of data for other less well-studied
and taxa habitats is a major concern for which significant progress
needs to be made[66].
Effective survey and monitoring to assess progress is thus a key
component of the process and while data is currently collected
by volunteers there still needs to be an effective co-ordination
of this effort. National Societies such as BC can mobilise volunteers
but without further support through the proposed National Biodiversity
Network much useful data will be lost.
Therefore Government should core fund the National
Biodiversity Network.
4.3 A key feature of the biodiversity process
is the development of a common agenda for the conservation of
the UK's biodiversity, shared by Government and the voluntary
sector alike. The delivery of these plans also needs to be shared
and a key mechanism for this has been the establishment of Species
and Habitat steering groups to ensure this partnership in implementation.
Despite the valuable guidance and series of workshops for lead
partners and agencies run by the DETR Biodiversity Secretariat
the steering group progress has been variable. In particular some
of the habitat groups have met infrequently and do not appear
adequately resourced both in terms of staff time and finance to
actually achieve the targets in the plans. There is little evidence
that the effective implementation of the Habitat plans is yet
seen as a core area for the hard pressed staff in several of the
agencies.
Lead agencies need to ensure staff are allocated
sufficient time and resources to co-ordinate the steering groups,
which should be seen as a key mechanism for the delivery of habitat
conservation in the UK.
4.4 It is unclear who has overall responsibility
if problems over implementation, lack of general commitment or
poor plan progress are manifest.
The DETR Biodiversity Secretariat should clarify
lines of responsibility and develop a mechanism for dealing with
any lack of commitment to the process.
5. OBSTACLES
TO EFFECTIVE
IMPLEMENTATION
5.1 Presently the Biodiversity process has
been instrumental in improving the voluntary approach to biodiversity
conservation but there is now mounting evidence that the lack
of a statutory duty is reducing the priority given to the process
within sectors of Government. This is particularly evident locally,
as many Authorities have not employed designated Biodiversity
staff to ensure delivery of the plans across the Authority because
the process does not have any statutory basis.
5.2 To ensure the long term political commitment
and the resources necessary to deliver the UK Biodiversity Action
Plan Butterfly Conservation believes that the process should be
given statutory underpinning. We believe this would give a duty
on Ministers and all public bodies to ensure the implementation
of the published plans across the various sectors of Government
necessary to ensure the biodiversity targets are being met.
The UK Biodiversity Action Plan process should
be given legal backing. Ministers and all public bodies, including
local authorities, should be given a duty to further the objectives
of published Species and Habitat Action Plans.
Stonger measures are needed to protect and enhance
the management of land, outside notified wildlife sites, that
supports priority species.
6. The importance of Policy issues
6.1 Many of the HAPs and SAPs have significant
policy components, and analysis of the reporting back forms indicate
the significance of agricultural policy in particular in delivering
the BAP objectives[67].
MAFF have made important changes to agri-environment schemes to
better enable them to contribute to the UKBAP, in particular developing
appropriate management tiers for priority species such as the
Marsh Fritillary as well as ensuring the presence of BAP species
are taken into account when assessing scheme entry. Agri-environment
schemes such as Countryside Stewardship have made an important
contribution but limitations on funding and the restricted scope
of these schemes has meant that for widespread but rapidly declining
species such as the March Fritillary they have not achieved significant
recovery.
The UK Government should press for at least
25 per cent of the EU agricultural budget to go to the Rural Development
Regulation (including agri-environment schemes) by 2005.
7. The reporting process
7.1 Butterfly Conservation looks forward
to the publication of the Biodiversity Millennium Report. As lead
partner we completed detailed assessment forms for the butterfly
and moth plans and commented on relevant habitat plan assessment
forms. The provisional analysis of the forms by the Biodiversity
Challenge Group suggests that many key issues for the future sucess
of biodiversity conservation will be raised. This reporting on
our successes and failures is a useful exercise and we hope that
future reporting will build on this experience. Future reporting
requirements for all those engaged in the process, including local
BAPs, need to be developed in good time for the next round of
reporting.
The UKBG should review the reporting process
and ensure the arrangements for the next round of reporting are
prepared well in advance of 2002. This process should also give
an opportunity for Local BAP initiatives to report.
60 Thomas J A (1991). Rare species conservation: case
studies of European butterflies. In: Scientific management of
temperate communities. British Ecological Society. Blackwell Scientific
publications, Oxford. Back
61
Asher et al. (In press). The millennium atlas of butterflies in
Britain and Ireland. Oxford University Press. Back
62
Green D (2000). The status of Lepidoptera in the New Forest. Butterfly
Conservation. Wareham, Dorset. Back
63
Warren M S (1992). The conservation of British butterflies. In:
The ecology of British Butterflies. Ed by Dennis R. Oxford University
Press. Back
64
Unpublished analysis by Biodiversity Challenge Group. Back
65
Asher et al. (In press). The millennium atlas of butterflies in
Britain and Ireland. Oxford University Press. Back
66
Unpublished analysis of Biodiversity Challenge Group. Back
67
Unpublished analysis by Biodiversity Challenge Group. Back
| 
