Memorandum submitted by the Country Land
and Business Association (N11)
EXECUTIVE SUMMARY
— The PSA target is an extremely demanding
one which is reliant on many issues including the economics of
agriculture, forestry and game management in the future. The CLA
raises the following specific issues:
— Attractive agri-environment schemes
are essential.
— More research is required into the
issues of moorland restoration and the effects of burning.
— De-coupling should remove the incentive
to overgraze but undergrazing and localised overgrazing may increase.
— Positive contact between English
Nature and land managers is essential and can be improved.
INTRODUCTION
1. The Country Land and Business Association
(CLA) has some 40,000 members who between them manage half the
rural land in England and Wales. With 43% of the SSSI area in
England being in private ownership our members have responsibility
for many of these sites which they have to consider alongside
their agricultural, silvicultural and other business interests.
Good stewardship of the countryside is also a priority for many
of our members and they are deeply committed to maintaining and
improving the conservation interest of their land. Issues relating
to SSSIs are raised with CLA regional staff or with the advisory
team based at our London headquarters. The collective experience
of the CLA and the practical implications for our members of conserving
SSSIs to the level of favourable condition means that we can make
a valuable contribution to this Inquiry. We are pleased to have
been given the opportunity to offer our comments on this very
important issue.
2. The terms of reference of the inquiry
are:
3. "The Committee will examine progress
made towards achieving Defra's Public Service Agreement (PSA)
target that by 2010 95% of all nationally important wildlife sites
should be in `favourable condition'. It will examine the role
played by various agencies in meeting the target, including especially
English Nature and local authorities, and will determine what
changes are needed to ensure that the target will be met."
GENERAL COMMENTS
4. The recent announcement that the management
of nearly 61% of SSSIs was meeting the PSA target (ie it was either
in favourable condition or unfavourable recovering) was encouraging
but still implies that more needs to be done if the target is
to be met (the PSA target does not exist in a vacuum; it implies
costs for at least some land managers if it is to be met).
5. Although there are several positive factors
which will assist progress, and these will be explored later,
there are also factors which may actually undermine the current
situation. With the conservation interest of the majority of SSSIs
reliant on traditional land management practice their future is
inexorably linked with the economics of agriculture, forestry
and sustainable game management. For woodland SSSIs low profitability
of timber production is removing resources needed for conservation
and high deer numbers pose risks to regrowth on restored coppice
stools, natural regeneration of woody species and the rich ground
flora. For grazed SSSIs we predict that undergrazing will become
more widespread as a consequence of decoupling of CAP support,
continuing low incomes from livestock production, a decline in
the numbers of appropriate livestock and a decrease in numbers
of skilled farmers and farm workers.
6. We would also like to highlight the fact
that the management of SSSIs to a high standard is sometimes reliant
on factors beyond the boundary of the holding and over which the
manager may have little or no control. Some examples would be
eutrophication, air pollution and rabbit and deer damage.
DEFINING THE
CONDITION OF
SSSIS
7. We are unclear as to what criteria or
factors are used in the definition of the five condition classifications
or what proportion of an SSSI unit would have to be in poor condition
for its classification to be detrimentally affected. It could
be that some generally well managed sites are not contributing
to the achievement of the PSA target because a minority of the
area is not meeting its conservation objectives.
8. Some land managers have also raised concerns
where an SSSI designation has conservation objectives which are
appropriate for the majority of the area but may not be appropriate
for all the features contained within the boundary. Disagreements
with land managers over the practicality and appropriateness of
these objectives may be a factor holding up English Nature accreditation
of some sites as in favourable condition or recovering.
9. Not all land managers agree with the
judgments of English Nature over the effects of particular levels
of grazing in the uplands and some question whether the requirements
for favourable condition are appropriate to the site or achievable.
Please refer to the section on overgrazing later in the document.
INCENTIVES FOR
POSITIVE MANAGEMENT
10. For many years an SSSI designation has
often been seen as a restriction to profitability, offering little
or no benefit to the land manager. The introduction of agri-environment
schemes such as the Environmentally Sensitive Area (ESA) schemes,
the Countryside Stewardship Scheme and English Nature's own Wildlife
Enhancement Scheme have helped to change this view by offering
payments for the delivery of environmental benefits. However,
in some cases, such agreements for a holding have not been focused
enough to address the needs of an SSSI contained within it. It
is also worth noting that payment levels within these schemes
are usually modest, have often favoured creation over existing
management and have not specifically rewarded SSSIs over less
valuable habitats.
11. Over one million hectares are designated
as SSSIs with approximately 410,000 ha publicly owned or owned
by private companies with statutory responsibilities and about
450,000 ha are owned by the private sector. Around 190,000 ha
(18% of the total) are intertidal habitats where agri-environment
agreements do not usually apply. Another 117,000 ha are woodland
SSSIs which would be eligible for the Forestry Commission's Woodland
Grant Scheme. Of the 743,000 hectares where agri-environment schemes
are applicable just 426,100 ha (source: DEFRA and English Nature)
are currently in an agreement. This means that for 43% of SSSIs
there is currently no positive incentive for the owner to manage
his land to achieve favourable condition.
12. A surprising statistic is that 40% of
the land currently not meeting the Government's PSA target is
in an agri-environment agreement. However this figure must be
considered with care. Often agri-environment agreements are prepared
on a whole farm basis and cover large parts of the holding. This
means that they may include an SSSI but may not be sufficiently
focused or have high enough payments to achieve favourable condition.
We firmly believe that a level of agri-environment funding that
recognises the realistic costs of SSSI conservation is essential
if the PSA target is to be met. CLA hopes that the new Higher
Level Agri-environment Scheme, to be introduced early in 2005,
will have a much greater focus on rewarding good management of
important features and more attractive payments to reward the
skill and time needed to deliver this. That would help to focus
land managers on achieving the environmental potential of their
SSSI and other land and should provide the payments.
PROVISION OF
ADVICE
13. Managers need to be made aware of the
value of SSSIs and how it can be maintained and enhanced through
their management. Effective and regular contact with English Nature
staff who have a good rapport with the owner and manager would
be the ideal. English Nature officially recognise that maintaining
goodwill and building on the knowledge and enthusiasm of land
managers is essential to the future of SSSIs and we would support
this concept of a partnership approach.
14. Unfortunately in practice there are
constraints on this partnership fulfilling its potential. Land
managers prefer to have long standing relationships with advisers
they can trust and this is particularly true for conservation
which is often regarded as being of a more sensitive nature. For
many managers regular changing of their EN contact inhibits this
relationship from developing and we believe that this is a significant
issue for many SSSIs. The fact that inappropriate scrub control
is the second most common problem affecting favourable condition
(1,332 sites) appears to highlight the need for a more effective
system of communication.
15. Associated with this problem is that
a minority of EN staff do struggle to communicate well with land
managers. Several members have reported their first contact with
EN staff has been after a problem has occurred and they have been
treated with a "guilty until proved innocent" attitude.
This has often been due to young and apparently fairly inexperienced
staff not yet having the confidence or experience to be able to
establish a rapport. If there is then also a wide difference of
opinion between EN and the land managers on what should be the
conservation objectives for the site it is no surprise that good
working relationships are sometimes absent.
16. In recent years English Nature has made
considerable efforts to work with land managers, highlight the
good results achieved on SSSIs and introduce new initiatives to
assist with management such as the Traditional Breeds Incentive.
This is appreciated but its success is likely to be limited if
more attention is not given to the staff issues we have highlighted.
CROW LAND
AND THE
RIGHT OF
ACCESS
17. Open landscapes such as heath, moor
and downland were included for a right of access under the CRoW
Act 2000. Land managers often have concerns about the effect this
will have on their management and enjoyment of the land. Where
SSSIs in unfavourable condition have a high tree cover which needs
to be cleared managers will be unwilling to undertake this work
for fear that the SSSI will then be designated as open land. When
their commitment and expense would be likely to result in greater
management pressures and a potential loss of privacy the reluctance
of such managers to achieve favourable condition is entirely understandable.
18. For sites that are already being managed
in good condition the introduction of CRoW access may threaten
the future of the site if significant additional pressures are
created and no resources are available to the manager to address
these. Some members have raised concerns that unmanaged access
could lead to localised erosion and disturbance to ground nesting
birds.
PRIORITY ISSUES
AFFECTING FAVOURABLE
CONDITION
19. We would like to focus on three key
issues which we believe are critical to this subject:
Overgrazing
20. Overgrazing is currently recorded as
the largest problem affecting the achievement of the PSA target.
This is usually associated with uplands and is linked to sheep
production where ewe subsidies have encouraged higher stocking
rates in some areas. Members report considerable concerns over
this issue which include:
21. There is often a presumption that sheep
numbers are at a record high and all uplands are at risk from
overgrazing. According to the National Sheep Association the national
flock now stands at seven million ewes whereas at the end of the
Second World War the figure was around six million and that was
after a period of significant decline. We may be trying to re-create
habitats that never existed in the extent and quality envisaged
by some EN staff. More investigation of what is actually achievable
on individual sites including consultation with local farmers
on historical management practices and site condition is needed.
22. Reducing stock numbers does not necessarily
lead to the desired effect and additional management may be required.
In some cases farmers have reduced stocking rates through agri-environment
agreements and then, when the desired effects have not occurred,
they have been pressured into reducing stocking rates further
even though some of their land may be suffering from undergrazing.
Given that reduced stocking does not always appear to produce
the desired benefits, at least in the short term, it is questionable
whether this approach should continue to be actively promoted
without more research and contact with the farming community.
23. Reducing stock numbers can result in
the enterprise becoming unviable and threaten the future of hefted
systems which can both have a major impact on the local economy
and hill communities. Hill farmers are very worried about this
and can be understandably concerned over the impacts of entering
agri-environment agreements, especially if they feel that some
of the targets are inappropriate. There is great concern that
a narrow focus on reducing livestock numbers could result in a
shortage of livestock and skilled labour which may be essential
for managing these habitats in the future.
24. Members' reports suggest that EN staff
sometime take insufficient notice of the knowledge and skills
of upland farmers and may seem unwilling to work with them on
the basis of a stepped approach to conservation improvement. We
have even heard of instances where a land manager has made an
application to an agri-environment scheme and the Rural Development
Service adviser dealing with the application has fallen out with
English Nature because the good proposals were not considered
radical enough to meet the conservation objectives for the site.
This is extremely worrying and does not foster the partnership
approach or the empowering of the land manager which the CLA believes
is fundamental to the delivery of high quality environmental benefits.
We are very concerned that pressure to meet the PSA target could
result in similar occurrences over the coming years which could
actually have counter-productive effects on the condition of the
SSSI.
25. We do not dispute that overgrazing can
be a major problem but the response from our members suggests
that the current approach to achieve environmental improvements
is not supported by many land managers. A more constructive partnership
is needed in some areas so that the experience, knowledge and
commitment of local land managers can be utilised. The de-coupling
of agricultural subsidies from 2005 should reduce the incentive
to keep such high sheep numbers which should make a very positive
contribution to reducing overgrazing per se. However we must raise
a note of caution here. Undergrazing of moorland leads to an increase
in coarser vegetation which can increase grazing pressure on the
remaining areas of more palatable vegetation. Without the labour
to move animals around the moor or control coarse vegetation we
may see localided overgrazing and undergrazing within the same
SSSI.
Undergrazing
26. Although undergrazing only contributes
to 5.54% of the SSSI unit area not meeting the PSA target it affects
1,161 sites, the third most common problem behind overgrazing
and inappropriate scrub control. Continuing low incomes and the
high demands of livestock farming have resulted in progressive
and worrying declines in sheep, cattle and farm labour in recent
years which show no signs of abating. The de-coupling of agricultural
subsidies from production which will be introduced in 2005 will
remove the incentive to maintain current numbers of sheep, suckler
cows and steers. Unless there is alternative encouragement through
the market place, including premium outlets, and/or agri-environment
schemes farmers may well decide to reduce stock numbers and possibly
labour. This could lead to further undergrazing due to the loss
of the grazing mouths and human skills essential to countryside
management. Many conservation organisations are extremely concerned
about this issue which is already a significant problem on many
environmentally important grazed habitats in the east and south
east of England. It should be noted that overgrazing in the uplands
is sometimes of a localised nature attributable to a lack of labour
to visit the moor and move animals around which would have occurred
a generation ago.
27. The cross-compliance conditions that
will be attached to the new single farm area payments in the future
will play a role in ensuring a minimum level of management. However
we believe it is the agri-environment schemes which are most appropriate
for SSSIs because they have the potential to address the specific
management requirements that are required on a site by site basis.
Moor Burning
28. Moorland fires are a major factor in
individual sites not meeting the PSA target. Careful burning is
often essential for grouse management and for maintaining a mosaic
of vegetation types which benefits many important bird and other
species. Burning is also carried out by graziers to restore the
quality of the grazing. Sometimes these fires do run out of control
but there is evidence that it is through accidents or arson that
the most damaging fires are caused.
29. With greater access to open land under
the CRoW Act, increasing problems of bracken encroachment and
the potential threat of undergrazing leading to an increase in
the area of coarser and woody vegetation the threat of burning
to SSSIs will grow.
30. Sustainably managed moorland provides
natural firebreaks because of the diversity of cover and younger
vegetation produced. Such areas will be even more important to
limiting the risk to SSSIs in the future but continued management
is reliant on economic grouse and grazing enterprises.
31. There is considerable debate over whether
some burning, particularly when it affects bog flushes, causes
significant damage or is beneficial. The initial conclusion is
that more research is needed, a theme that has been raised earlier
in the context of how to restore grazed moorland.
12 March 2004
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