Condition
assessment
17. In 2003, EN concluded the first complete assessment
of the current condition of all SSSIs in England.[19]
EN described the assessment procedure as follows:
We divide SSSIs into 'management units'—there
are about 22,000 units on 4112 SSSIs. At this unit level, condition
is assessed against a set of ecological objectives identified
to maintain the special habitat and species features in a healthy
state. This level of assessment in underpinned by monitoring special
features to a common UK standard co-ordinated by the JNCC [Joint
Nature Conservation Committee]. English Nature validates the condition
assessments by more detailed monitoring of particular special
features on a sample of SSSIs.[20]
18. The Joint Nature Conservation Committee has published
13 of 18 intended volumes of guidance on standards for SSSI condition
assessment. The remainder are due in 2004/5.[21]
EN says that the full assessment standards will be made readily
available to the public once the JNCC guidance is complete.[22]
Land can be classified as being in 'favourable', 'unfavourable
recovering', 'unfavourable no change', or 'unfavourable declining'
condition. The very small number of sites where there has been
fundamental and lasting damage can be described as 'part destroyed'
or 'destroyed'. Those areas classed as favourable or unfavourable
recovering are deemed to count towards the PSA target.
19. Although understanding of what is meant by favourable
condition appears to be good among major landowners and at senior
levels, there is some evidence that it may not be as clear to
some of those involved in managing SSSIs on a daily basis. The
Country Land and Business Association said that it was "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".[23]
The Association of National Park Authorities recommended that
EN should take the lead in developing a common understanding of
favourable condition, and how it applies in practice.[24]
20. Some landowners have expressed concern about
a lack of consultation and transparency in arriving at the condition
criteria and during the assessment process.[25]
Water UK said:
there seems to be some inconsistency across the
country about the rigour with which these assessments have been
made … there also appears to have been an over reliance on
the precautionary principle and a lack of sound science …
certainly for our sector we feel that there has not been enough
interactive dialogue with the companies as the assessment was
made.[26]
21. EN told us that it attached great importance
to the consistency of and scientific basis for condition assessments
and was confident that at the level of national policy these were
"broadly correct". It said that for some sites or some
habitats, where the science was underdeveloped or sites had not
been assessed for some time, there was room for discussion, and
highlighted freshwater ecosystems as an area where the science
was still in its infancy.[27]
22. If SSSI landowners
and managers are to play an active and willing role in the care
of SSSIs it is vital that they understand the basis of English
Nature's assessment of their land. We welcome the publication
of the assessment criteria. In future assessment rounds, English
Nature should ensure that it explains the criteria and the assessment
methods to landowners prior to embarking on the assessment, and
should hold a series of regional conferences to do so. We recommend
that English Nature discuss the assessment of condition with landowner
or occupier before publishing the result of the assessment. If
the criteria are to be modified in future, it would be helpful
to involve land managers in the process at an early stage.
23. It is clearly
important that the criteria are supported by sound science. Where
the science is still uncertain, efforts should be made to clarify
the issue as soon as possible and the expertise of land managers
should inform the process.
24. Some witnesses expressed concern that in assessing
the condition of SSSIs, EN had in mind some putative ideal state
rather than the state of the land when it was designated as a
SSSI. For example, Water UK said: "we are not convinced that
the assessment of condition was in all cases effectively related
to the original reasons for notification".[28]
The Country Land and Business Association (CLA) argued that EN
might be seeking to create conditions that had never previously
existed.[29] We
take the view that SSSI condition should bear some relation to
the state the site was in when it was designated, though without
ruling out the prospect of improvement in future.
25. We received anecdotal evidence of poor relationships
between some landowners and EN staff. It was felt that it was
particularly hard to build up a good relationship when EN personnel
changed frequently.[30]
EN said that it took these issues seriously, but pointed out that
in general staff turnover was low and staff were trained in "understanding
customer needs and influencing and negotiating skills".[31]
Good relationships between SSSI
owners and managers and English Nature staff are crucial. We welcome
the regular staff training that English Nature has introduced
and recommend that it keep this area under review.
Factors
causing unfavourable condition
26. As well as describing the condition of SSSIs,
EN has identified the factors that it considers are responsible
for unfavourable condition. The two factors affecting the greatest
area of SSSI land are overgrazing, which affects more than
45% of SSSI land in unfavourable condition, and inappropriate
moorland burning, which affects 24%.[32]
27. Some of our witnesses disagreed with EN's assessment
of the impacts of both grazing and moorland burning. The CLA argued
that the number of ewes in England is not much higher than it
was at the end of the Second World War. Furthermore, they argued
that reducing stock numbers does not always have the desired effect
on the site.[33] In general
though, there seemed to be a consensus that changes to the Common
Agricultural Policy had largely removed incentives for farmers
to overstock their land.
28. The Moorland Association is "very firmly
of the view that English Nature are substantially mistaken in
their reasoning and in their allegations as to the damage carried
by controlled burning".[34]
EN accepted that it differed from the Moorland Association over
some aspects of the ways moors should be managed and that this
arose from the two organisations' different, but overlapping,
aims: the Moorland Association's members manage moorland primarily
for grouse shooting and EN's assessment of moorland SSSI condition
is based on a wider range of species. EN is working with the Association
and others on a review of the burning code of best practice. It
is important that the various parties involved can reach a common
science-based understanding of the impacts of burning on moorland
and we expect that the burning review group will achieve this.
English Nature should inform us of the review's conclusions when
they have been reached.
19 England's best wildlife and geological sites, English
Nature, 2003 Back
20
England's best wildlife and geological sites, English Nature,
2003. p. 115 Back
21
Ev 43 [English Nature] Back
22
Ev 43 [English Nature] Back
23
Ev 33 [CLA] Back
24
Ev 2 [ANPA] Back
25
Ev 86 [NFU], Ev 107 [Moorland Association] Back
26
Ev 77 [Water UK] Back
27
Q122 Back
28
Ev 77 [Water UK] Back
29
Ev 34 [CLA] Back
30
Ev 33 [CLA] Back
31
Q129 Back
32
England's best wildlife and geological sites, English Nature,
2003, pp 15-19 Back
33
Ev 34 [CLA] Back
34
Ev 109 [Moorland Association] Back
