Memorandum submitted by the British Ecological
Society (N3)
The BES and the Efra consultation
1. The British Ecological Society (BES)
is the leading UK learned society to support, and promote ecological
science. Founded in 1913, the BES is an independent and charitable
body with some 4,000 members. It publishes scientific journals
and holds scientific meetings as well as works on education and
policy matters. The BES is also a member of the Biosciences Federation
and is a specialist Affiliated Society to the Institute of Biology
which may be submitting some overall comments. This response focuses
particularly on the ecological dimensions. The BES welcomes the
Select Committee's inquiry into the Protection of Sites of Scientific
Interest which is most timely given UK undertakings to the Biodiversity
Convention and the related Defra Public Service Agreement (PSA)
target of 95% of all nationally important wildlife sites to be
in favourable condition.
SSSI assessment is new and challenging but should
lead to genuine benefits
2. The assessment of SSSIs is something
new for the principal UK agencies concerned with wildlife, geological
and countryside conservation (neither NCC or NC before had any
such system). It is a challenging task but should lead to genuine
benefits for both conservation and allied benefits (such as quality
of life through improved environmental quality) provided assessments
are a) carried through thoroughly and properly, and b) that there
is follow-up action to ensure that where possible (and sometime
it will not be possible) that those SSSIs in an unfavourable condition
are improved.
New resources will be required for this activity
and Departmental scientific funding has been the subject of previous
Parliamentary concern
3. As stated, this assessment activity will
be new to English Nature. Further, while some SSSIs are already
being managed satisfactorily, those that are not will require
resources for proper management. Both these require "new
money" funding. Given that overall MAFF/Defra R&D has
declined in real terms for many years (cf. Commons Science
and Technology Committee reports Governmental Expenditure on
R&D (2000) and Are We Realising Our Potential?
(2001) it is hoped that securing appropriate resources for the
assessment and, where needed, the protection of SSSIs will not
prove difficult.
Science underpinning assessment is essential for
policy and conservation value
4. Regarding assessment procedures, current
methodologies are largely experience-based: while we understand
that English Nature is reasonably confident that they are robust,
it is important that they are backed by suitable quality assurance
and evidence-based validation procedures. Pressure to get the
basic assessments done should not lead to the scientific underpinning
being skimped. If the assessment is not properly scientifically
underpinned then the exercise's value in both policy and conservation
terms will be severely undermined. Conversely quality assurance
and evidence-based validation provides credibility to, as well
as competency with, land managers to know what management works
and what does not, through being able to provide the evidence
along with advocacy.
An unfavourable but accurate assessment is far
more value than a worthless favourable but inaccurate assessment
5. The BES stresses the above point to the
Select Committee as it is important that political pressures to
meet the target must not undermine the assessment process: it
would be better if we have reached only 85% favourability assessment
by 2010 if the assessment is fair and sound, rather than that
the figures are fudged to make it 95%. If the assessment presents
an erroneous position then nobody will be able to ascertain what
action really needs to be taken for maximum efficacy and the losers
will be biodiversity and its associated natural heritage as well
as the nation.
English Nature is being reorganised and we must
ensure this SSSI issue continues
6. We are aware that the principal Defra
agency concerned with ecological SSSIs, English Nature, is currently
the subject of proposals for reorganisation under the outcome
of the Haskins enquiry. The evaluation of assessment processes
needs to be continued and carried through with the same degree
of commitment by the new organisation.
More evidence is required as to SSSIs' deterioration
but there are co-ordination and resource limits
7. There are a number of Defra Agency reports
on SSSIs as well as the state of the natural environment. These
outline what are considered to be the major pressures on the SSSIs,
for example overgrazing of moorland SSSIs. While in many cases
the general evidence for SSSI deterioration is clear, there is
a need to build up more examples through systematic review of
the current evidence and, if necessary, experimental testing of
cause-effect relationships for some impacts in some habitats.
There are resource limits on how far English Nature and other
Defra Agencies can move down this path on their own; it would
be helpful if Defra, and other Government Departments with responsibility
for land use (such as the Office of the Deputy Prime Minister
with its planning, and local and regional government commitments)
devoted more of their science budgets to assessing the impact
of activities under their control (agriculture, water abstraction,
development etc.,) on protected sites and the potentials for future
optimum management.
A cross Agency and pan-Departmental strategy is
required
8. This will necessitate a) cross Agency
strategy within Departments such as Defra, and b) pan-Departmental
strategy. With regards to the former "a", the BES welcomes
Government Departments creating their own scientific advisory
councils such as the one announced in February to serve Defra.
With regards to "b", we note that the Office of Science
and Technology within the DTI has responsibility for cross-Departmental
strategy for science and it may be that this is well placed to
orchestrate the scientific assessment that will be necessary to
determine effective future management requirements.
Research priorities include those on site as well
as landscape level pressures
9. With regards to the outcome of any particular
SSSI assessment, the pressures on SSSIs can be roughly divided
into those that can be ameliorated (at least in principle) by
action at the site scale—eg getting grasslands grazed or
coppicing woodland—and those that may need action at a landscape
scale such as those pressures arising out of the impact of diffuse
pollution, landscape fragmentation, or deer populations. There
is a particular need for better integration of ecological knowledge
of landscape-scale processes with the practicalities of land-use
policies and management. For example is it better to put effort
into creating large areas of semi-natural habitat around existing
sites to buffer them rather than attempting to deal with problems
by action within the sites? These questions are not trivial and
necessitate proper examination.
Uniformity of commitment is required by agencies
and their Departments
10. The BES is under the distinct impression
that some agencies, and their respective Departments, appear to
have made a more public commitment to meeting the PSA target than
others, eg the Forestry Commission and Ministry of Defence who
were cited in the recent English Nature report England's Best
Wildlife and Geological Sites, 2003, (see pages 44-46), and it
was also disappointing that the Countryside Agency did not recognise
the importance of science when determining its strategy for the
South Downs National Park.
We stress the above cross agency and pan-Departmental
points
11. The BES emphasises the cross agency
and pan-Departmental points in the above paragraphs (8-10) as
the terms of reference for the Committee's inquiry refer specifically
to the contribution of English Nature and local authorities to
the PSA target. We hope we have adequately illustrated that significant
and co-ordinated contributions from others are also required.
It should also be noted that there may be conflicting policy goals.
For example, the primacy of agricultural factors (overgrazing,
moor burning, drainage, undergrazing, ditch management) in the
top ten factors leading to unfavourable SSSI condition reinforces
the desirability of Defra reviewing the degree to which it can
contribute to meeting the conservation PSA target. Local Authorities
(hence the ODPM) do have a key role with respect to certain sites
or types of site, but by area issues to do with planning etc.,
are lower down the list in terms of negative SSSI impact.
A UK strategy for conservation sites is also required
to meet UK commitments
12. The above point regarding competing
policy goals complements that of the need to have a co-ordinated
and strategic approach to implementing conservation goals. For
example, we mentioned in passing above (paragraph 1) the UK commitments
to the Biodiversity Convention. This has wider implications for
the delivery of biodiversity objectives than the protection and
management of SSSIs, which are simply representative of the best
UK habitats. We therefore venture that while the inquiry is about
the PSA target for SSSIs, this should be seen in conjunction with
the commitments of different departments and agencies for the
systemic, rather than the site-based, deliver of Habitat and Species
Action Plans under UK and European Biodiversity Action Plans.
For some habitats and species achieving the SSSI PSA target will
also make a substantial contribution to the HAP/SAP targets—for
example of 60% of lowland heath is within SSSIs. For other habitats
such as ancient woodland (only about 15% SSSI) additional action
will be needed outside the SSSI series. Finally it might be useful
for the Committee to bear in mind that the UK's commitments to
biodiversity also relate to Scotland, Northern Ireland, and Wales
and that any English contribution is being made as part of a broader
effort.
Assessment needs to account for on-going change
13. We wish to make a point as to the dynamic
nature of the environment. The term "SSSI assessment",
could imply the ability to define what the state (structure, composition
etc) is of particular features of SSSIs compared to what they
might be. This may be seen by some as rather static and deterministic.
There must be scope built into the system to take account of changing
environmental conditions—for example climate change. The
SSSI series will continue to be the cornerstone of nature conservation,
but there may be circumstances where the species and habitat features
for which the sites are currently scheduled may no longer be present,
or at least not in abundance. The objectives for sites and the
condition assessment targets themselves may therefore need to
be periodically reassessed to ensure that they are still appropriate.
Assessment should help prepare for the future
14. Further to this last, it would be useful
to prepare for the future. We can anticipate with some confidence
that some pressures (such as arising from climate change or continuing
landscape fragmentation due to development) will continue. Not
only do we need to assess so as to properly plan and then protect
existing SSSIs, but we need to anticipate now how we are likely
best to do this in the longer term future if UK's ecological heritage
is to be maintained, if not enhanced, and have longevity.
Systematic research remains of concern to biologists
and Parliamentarians, Defra has policy-driven R&D responsibilities
15. Importantly, the BES wishes to stress
that the initial identification of ecological (as opposed to geological)
SSSIs, their assessment and the determination of the nature of
their ecology required for management considerations, depends
on the science of systematics (species identification and their
evolutionary relationships). This whole issue is just one example
of the need for systematics in the policy-driven R&D context.
Government Departments are responsible for policy-driven R&D
(as opposed to fundamental, basic and blue skies R&D which
is supported by the "Science Base" from the Research
Councils from the DTI's Office of Science and Technology (OST)).
However for some two decades support for systematics has markedly
declined. This is of considerable concern to the UK whole-organism
community. This concern has been further shared by Parliamentarians.
For example, the Lords Select Committee for Science and Technology
has conducted two inquiries into the decline of systematic research:
What on Earth? The Threat to Science Underpinning Conservation
(2002) and the Dainton report (1992). If Defra is to roll out
UK policies related to biodiversity conservation then it needs
to be aware of the need to support systematics research to ensure
that the appropriate expertise is available to carry forward its
policy commitments.
Assessment must not impede on-going development
of the SSSI series
16. There is a perception that the process
of new SSSI designation and existing SSSI-enlargement has effectively
stalled. We would not want the process of assessment to stifle
the overall "SSSI programme" (see paragraph 6). This
is particularly important in the light of recent studies and reviews
emphasising the need for a dynamic and responsive network of designated
sites to allow species of conservation importance to adapt to
climate change (see paragraph 13).
12 March 2004
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