Memorandum submitted by the Institute
of Biology (N4)
1. The Institute of Biology (IOB) is the
independent and charitable body charged by Royal Charter to further
the study and application of the UK's biology and allied biosciences.
It has 14,000 members and over 60 specialist learned Affiliated
Societies (see www.iob.org). The IOB's Environment Committee draws
upon Members with expertise in ecology, conservation, countryside
management, soil biology and marine science. The British Lichen
Society contributed to this response.
SUMMARY
2. The main points of this response are:
| (i) | The IOB welcomes the Select Committee's inquiry into the protection of Sites of Special Scientific Interest (SSSIs) (paragraph 3).
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| (ii) | Quality assurance mechanisms should be in place to ensure that SSSI assessments, such as the Common Standards Monitoring (CSM) process undertaken by JNCC, produce valid and usable results (paragraph 6).
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| (iii) | If the input of local authorities in protecting and managing SSSIs is to be increased in future then they will have to make a major investment in skilled manpower (paragraph 7).
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| (iv) | It should be ensured that the proposed reorganization of English Nature's responsibilities do not affect the protection, management and monitoring of SSSIs (paragraph 8).
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| (v) | The original citation of an SSSI may not reflect the true biological importance of a site and should be reviewed regularly as new information comes to light (paragraph 9).
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| (vi) | Lower plants can be an important part of an SSSI's biodiversity but may not be considered in CSM assessment processes (paragraph 10).
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| (vii) | Defra and other government departments with responsibility for land use should devote more of their science budgets to assessing the impact on SSSIs of activities under their control (paragraph 11).
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| (viii) | Defra's PSA target on SSSIs will not be met without the provision of workers skilled in systematics and taxonomy. However, there has been little investment in this area in recent years and it is in danger of extinction (paragraph 12).
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BACKGROUND ON
SSSIS
3. The IOB welcomes the Select Committee's inquiry into
the protection of Sites of Special Scientific Interest (SSSIs)
in relation to Defra's Public Service Agreement (PSA) target that
by 2010 95% of all nationally important wildlife sites will be
in "favourable condition". The inquiry terms imply that
the Committee thinks the PSA target will not be met under current
conditions (ie "and will determine what changes are needed
to ensure that targets are met").
4. The Joint Nature Conservation Committee (JNCC) states
on its website that one of the key responsibilities of the statutory
nature conservation agencies in the UK [English Nature (EN), Scottish
Natural Heritage (SNH) and the Countryside Council for Wales (CCW)]
is the identification and protection of a series of sites intended
to conserve important wildlife and earth science features. Once
sites have been designated, the country agencies work with owners,
occupiers and others to secure their management and protection.
In 1998, JNCC agreed on common standards throughout Britain for
monitoring features on designated sites, and calls this process
Common Standards Monitoring (CSM). [8][Although
"Site Condition Monitoring" appears to be the term used
by EN, CCW and SNH.] The process works at the "interest feature"
level rather than the site level, and such features are identified,
monitored and reported separately. The first six-year cycle began
in 1999 and the first results are expected in late 2005. The results
are intended to identify general problem areas rather than produce
detailed statistical analyses.
5. In the interim, English Nature has used a different
method to report that 61% of SSSIs are currently meeting the PSA
agreement across England. [9]Rather
than looking at interest features the agency has broken down the
sites into "management units" to produce this figure.
ISSUES TO
BE CONSIDERED
6. The collection of data for CSM has been a new initiative
and a learning process for all involved. Quality assurance mechanisms
should be in place to ensure that SSSI assessments produce valid
and usable results. Approaches to data collection processes in
SSSIs seem to differ slightly between the three nature conservation
agencies and between regional offices of English Nature. In some,
extensive and sometimes complex protocols have to be completed
by a third party consultant or specialist, while in others, no
such paperwork is involved. Also, assigning "favourable status"
to an SSSI relies upon subjective data collection methods. This
all implies a potentially variable result in the quality of the
assessments. As a separate point, it is important that the definition
of "favourable status" is not too prescriptive in order
to adequately represent the range of national variation in UK
habitats.
7. It is not clear that local authorities are playing
any part in CSM at present. If the input of local authorities
in protecting and managing SSSIs is to be increased in future
(perhaps in line with the recent Rural Delivery Review by Lord
Haskins) then they will have to make a major investment in skilled
manpower. The resources required to monitor the condition of SSSIs
are significant. Much has already been invested but it is vital
that sufficient funds are allocated to ensure the job is done
properly.
8. We are aware that English Nature is currently the
subject of proposals for reorganisation under the outcome of the
Lord Haskins enquiry. The protection, management and monitoring
of SSSIs needs to be continued and carried through with the same
degree of commitment in the new organisation.
9. The CSM process concentrates on those habitat and
species features that were "notified" in the original
citation of the SSSI, but they ignore other features which may
also be significant, or which have emerged as significant since
the first citation. Due to historical and perhaps poorer quality
data, the original citation may not reflect the true biological
importance of a site. SSSI citations need to be reviewed regularly
as new information comes to light.
10. Related to point 9, currently there is no CSM guidance
for monitoring lower plants in SSSIs, such as bryophytes (mosses
and liverworts), lichens, fungi and algae. Lichens are often important
features of heathland, but the decline of lichen populations may
not be considered in CSM. The deterioration through agricultural
nitrogen pollution of rock lichens would not be mentioned in the
SSSI citation for a heathland, and as the flowering plants would
be unaffected, the feature could be registered as favourable.
Lower plants are in danger of being overlooked by spot checks
on key species to assess biodiversity and left unprotected.
11. Overgrazing, moor burning, drainage and air pollution
are the most common factors cited by English Nature for an SSSI
being in an adverse condition. [10]These,
and other factors such as diffuse pollution, arise from activities
that often fall outside the remit of the nature conservation agencies.
It would therefore be helpful if Defra and other government departments
with responsibility for land use devoted more of their science
budgets to assessing the impact of activities under their control
(agriculture, water abstraction, development, etc) on SSSIs and
the potentials for future optimum management.
12. As highlighted by the 2003 House of Lords report
"What on earth?"[11],
there has been little investment in systematics and taxonomy over
recent years and career prospects in this area are not perceived
to be good. There has been a demonstrable decline in the teaching
of systematics and taxonomy throughout UK universities, colleges
and museums. Trained and experienced staff in museums are not
being replaced on retirement. Within 5-10 years the subject will
have disappeared from university curricula and experts will be
virtually extinct in most UK institutions. However, these areas
of research underpin vital disciplines such as conservation and
ecology and Defra's PSA target on SSSIs will not be met without
skilled workers in these areas. The Government has failed to increase
funding to the major systematics institutions, but it has pledged
to set up a body to identify priority areas of biodiversity for
which taxonomic research is most needed. We hope the work required
to meet the PSA target on SSSIs will go towards emphasising the
need for more funding in this area.
13. Any conclusions of the inquiry should be communicated
to Scottish Natural Heritage or the Countryside Council for Wales
as they may influence the agendas for conducting their own parts
of the CSM programme.
15 March 2004
8
JNCC. A statement on Common Standards Monitoring. 1998. Available
at: http://www.jncc.gov.uk/csm/statement/Default.htm Back
9
Englsh Nature. SSSI condition summary-compiled 01 Feb 2004. Available
at: http://www.english-nature.org.uk/special/sssi/reportAction.cfm?Report=sdrt15&Category=N&Reference=0 Back
10
Englsh Nature. Reasons for adverse condition summary-compiled
01 Feb 2004. Available at: http://www.english-nature.org.uk/special/sssi/reportAction.cfm?Report=sdrt17&Category=N&Reference=0 Back
11
House of Lords Select Committee on Science and Technology. What
on Earth? The Threat to the Science Underpinning Conservation:
The Government's Response and the Committee's Commentary.
June 2003. Back
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