House of Commons - Environment, Food and Rural Affairs

Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by the Wildlife Trusts (N16)

EXECUTIVE SUMMARY

1. The Wildlife Trusts believe that work on SSSIs should therefore not simply be seen as an end in itself, but as one important tool that contributes to national targets for habitats and species and helps to meet our international obligations.

2. We strongly recommend that Local Site systems are given statutory underpinning to ensure they are in place and operate effectively. We also recommend that clear guidance regarding the structure, status and management of Local Site systems and resources to run them are made available, to assist in the favourable condition of SSSIs.

3. The Wildlife Trusts believe that while SSSIs provide a valuable tool for conservation in the terrestrial environment, better legislation and policy is required for the marine environment if we are to safeguard all the UK's biodiversity.

4. We consider this to be a challenging target and urge Government to maintain focus on it even though it may prove hard to achieve. The target sends out a powerful message of the Government's commitment to biodiversity and provides a strong statement of intent about the importance we should all attach to this work.

5. We congratulate English Nature on completing the assessment of the condition of all SSSIs in March 2003, as a major body of work that sets the baseline for future activity towards this target. We also greatly welcome the open and supportive approach that English Nature has adopted towards sharing information on SSSI condition and assisting organisations in moving towards the target.

6. We believe that English Nature must identify and address any problems with consistency of approach to ensure that condition assessments are robust and the information reliable.

7. The Wildlife Trusts believe that we should be careful in how we apply the classification of "unfavourable recovering" to ensure that it accurately reflects the status of sites moving towards the target and is not simply used as a means of boosting the figures for "favourable" status.

8. We would expect organisations with a specific statutory duty to further the conservation and enhancement of SSSIs to be taking this responsibility seriously and applying adequate resources and expertise towards it. The Wildlife Trusts therefore congratulate those section 28G bodies with a performance approaching 88% of sites in favourable condition, but would like to see all such bodies taking a lead by demonstrating clear commitment and funding to the target.

9. We believe that the voluntary sector bodies have made a serious undertaking to help meet the Government's SSSI target and are making good progress in working towards achieving it.

10. We would like to ensure that within the current review of Defra that funding to the voluntary sector for ongoing maintenance of sites in favourable condition in addition to support to bring additional sites to this status is not lost

11. If this good work is to continue and progress against the target for smaller landowners is to be improved, it will be necessary to increase the funding available to English Nature for SSSIs and ensure better targeting of agri-environment schemes to these sites

12. The real test for the collective commitment to the SSSI target comes with the major policy blockages that are largely outside the control of an individual landowner and can only be dealt with by major legislation, policy or funding changes across Government.

13. Government therefore needs to focus its effort on these key policy blockages and show real resolution in dealing with them. These should be integrated into the work programme of existing policy groups, in particular the Implementation Groups of the England Biodiversity Strategy, so that priorities are integrated and addressed.

14. The Wildlife Trusts believe that the "High Level Group" provides an opportunity for all appropriate Government Departments and agencies to demonstrate their commitment to meeting the SSSI target and show their contribution to addressing the key policy blockages.

15. In the current Defra Modernisation of Rural Delivery process there is a clear role for Defra and its agencies to ensure commitment to and delivery of biodiversity targets (such as the SSSI target) across Government.

16. In the current Defra Modernisation of Rural Delivery process there is a clear role for Defra and its agencies to ensure commitment to and delivery of biodiversity targets (such as the SSSI target) across Government.

17. We also believe that at the regional level the protection, conservation and enhancement of our natural heritage need to be better recognised with improved resourcing, structures and procedures for biodiversity.

18. We believe that Defra and its agencies should do more across Government and by building capacity within the voluntary nature conservation bodies to assist in engaging people in biodiversity.

19. The Wildlife Trusts believe that greater recognition of this contribution within those relevant Government departments and agencies is needed to increase commitment to the SSSI target.

INTRODUCTION

1. The Wildlife Trusts welcome the opportunity to submit written evidence to the House of Commons Environment, Food and Rural Affairs Committee inquiry into Protection of Sites of Special Scientific Interest.

2. The Wildlife Trusts are a unique partnership of 47 Wildlife Trusts and Wildlife Watch, the junior branch, covering the whole of the UK, Isle of Man and Alderney. The Partnership campaigns for the protection of wildlife and invests in the future by helping people of all ages to gain a better appreciation and understanding of nature. Collectively, The Wildlife Trusts have approximately 560,000 members and manage almost 2,550 nature reserves, covering more than 80,000 hectares of land ranging from inner city urban sites to the UK's finest wildlife areas.

The Wildlife Trusts will be focussing our evidence on six main areas where we have significant experience:

— SSSIs as a conservation tool.

— The PSA target and condition assessments.

— Performance against the PSA target.

— Major factors causing unfavourable condition.

— The role of Defra.

— Wider understanding and engagement in the target.

Further references on these and other areas are provided in Annex 1.

THE WILDLIFE TRUSTS' INVOLVEMENT

3. The Wildlife Trusts' purpose is the conservation of UK biodiversity and we are heavily involved in protection of SSSIs through work at both the local and national level. As a Partnership we own or manage approximately 700 SSSIs covering an area of about 40,000 hectares in England. We are also involved in the development and delivery of the UK Biodiversity Action Plan (BAP), England Biodiversity Strategy and Local BAPs, all strategic documents that impact on the protection of SSSIs. As part of the UK BAP we act as lead or joint lead partner for 23 species as well as sitting on numerous steering groups for other priority species and habitats. In addition, we are intimately involved in co-ordinating work on Local Wildlife Sites and play a lead role in establishing and operating Local Site systems.

4. The Wildlife Trusts are also represented on the Defra Major Landowners Group and are working closely with English Nature and other partners. As an organisation, we have made a commitment to help meet the Government's SSSI target on land that we own or manage, as this is considered a core part of our work and a useful indicator of progress.

SSSIS AS A CONSERVATION TOOL

5. The 4,112 Sites of Special Scientific Interest in England covering an area of about one million hectares represent some of the most important wildlife sites in the country. They are home to UK and European priority species and habitats and bringing these sites into favourable condition will play a major part in safeguarding the future of our wildlife.

SSSIs provide an important contribution to the implementation of the strategic approach to conservation in the UK, through the UK Biodiversity Action Plan and England Biodiversity Strategy. The UK BAP represents the Government's response to Article 6 of the 1992 Convention on Biological Diversity and our international commitment to conserve and enhance our biodiversity. The Wildlife Trusts believe that work on SSSIs should therefore not simply be seen as an end in itself, but as one important tool that contributes to national targets for habitats and species and helps to meet our international obligations.

6. However, our conservation effort should not stop with the network of SSSIs. These sites only make up 7% of the land area of England and consequently, most of our biodiversity lives outside these sites. This can be seen most clearly in an individual county such as Leicestershire where only 2% of the land area is made up of SSSIs. Although SSSIs are increasingly effective as a site based conservation tool, any effective approach to maintaining biodiversity will need to have clear mechanisms to ensure the protection and enhancement of biodiversity outside designated sites. We must complement work on SSSIs with conservation measures in the wider countryside to ensure that we do not simply create isolated pockets of biodiversity in protected sites that are no longer viable as the areas surrounding them become sterile.

7. In particular, Government should recognise the substantial contribution made by Local Site systems to the conservation of our biodiversity, including SSSIs. The series of non-statutory Local Sites comprises more than 35,000 sites in England, and many Local Sites are in fact of SSSI quality because SSSIs are only a representative sample of sites that meet this standard. The nationally important network of Local Sites complements legally protected sites by maintaining wildlife corridors, linking sites, providing reservoirs of biodiversity from which SSSIs can be replenished and acting as buffer zones.

8. The Wildlife Trusts' recent survey of Local Site systems[16] shows that only 8% of systems in England are currently operating to best practice standards and that 95% have inadequate resources to operate effectively. We have also shown that Local Sites are still being lost or damaged at an alarming rate[17], and this will impact on the integrity of the wider countryside and the condition of SSSIs. We strongly recommend that Local Site systems are given statutory underpinning to ensure they are in place and operate effectively. We also recommend that clear guidance regarding the structure, status and management of Local Site systems and resources to run them are made available, to assist in the favourable condition of SSSIs. Recommendations on guidance for operating such systems have been provided by The Wildlife Trusts. [18]

9. The 4,112 SSSIs currently designated are all terrestrial sites and the current view is that SSSIs are "terrestrial" designations. Despite priority marine habitats being highlighted in the UK BAP, legislation to protect and enhance our marine environment is weak. Issues such as pollution, industry and development are threatening our seas, resulting in whole marine ecosystems suffering serious damage. [19]The Wildlife Trusts believe that while SSSIs provide a valuable tool for conservation in the terrestrial environment, better legislation and policy is required for the marine environment if we are to safeguard all the UK's biodiversity.

THE PSA TARGET AND CONDITION ASSESSMENTS

10. The Wildlife Trusts welcome the establishment of the PSA target to bring 95% by area of all nationally important wildlife sites into favourable condition by 2010. We believe that a targeted approach to UK conservation is essential for focusing effort and resources on the highest priorities. We consider this to be a challenging target and urge Government to maintain focus on it even though it may prove hard to achieve. The target sends out a powerful message of the Government's commitment to biodiversity and provides a strong statement of intent about the importance we should all attach to this work.

11. We congratulate English Nature on completing the assessment of the condition of all SSSIs in March 2003, as a major body of work that sets the baseline for future activity towards this target. We also greatly welcome the open and supportive approach that English Nature has adopted towards sharing information on SSSI condition and assisting organisations in moving towards the target.

12. However, we have experienced some cases where there may be inconsistencies in the way that different English Nature teams interpret condition assessments and reasons for adverse condition, and would be concerned if this is more than a few isolated incidents. For example, this could mean the classification of sites as "favourable" in one area when over a border sites in a similar condition are classified "unfavourable". It could also result in a temptation to classify some unfavourable sites as "favourable" or "unfavourable recovering" in an endeavour to meet the target rather than reflecting their true status. We believe that English Nature must identify and address any problems with consistency of approach to ensure that condition assessments are robust and the information reliable.

13. Similarly, we believe that there are concerns in considering the classification "unfavourable recovering" within the category of "favourable". It may be that major threats have been removed and remedial action is included in management plans for sites (which would warrant a classification as "unfavourable recovering"), but this is not the same as sites having reached favourable condition on the ground. The Wildlife Trusts believe that we should be careful in how we apply the classification of "unfavourable recovering" to ensure that it accurately reflects the status of sites moving towards the target and is not simply used as a means of boosting the figures for "favourable" status.

PERFORMANCE AGAINST THE PSA TARGET

14. Current information on performance against the PSA target shows that some 58% of SSSIs are in favourable condition. [20]To analyse this in more detail it is helpful to group performance into that of section 28G bodies (under the CROW Act, ie statutory, public and private bodies), voluntary bodies and individual landowners.

15. Performance of section 28G organisations shows considerable variation in their progress towards the target (approximately 37%-88% sites in favourable condition). While we recognise that not all of the factors causing unfavourable condition will be within the immediate control of these bodies, we would expect organisations with a specific statutory duty to further the conservation and enhancement of SSSIs to be taking this responsibility seriously and applying adequate resources and expertise towards it. The Wildlife Trusts therefore congratulate those section 28G bodies with a performance approaching 88% of sites in favourable condition, but would like to see all such bodies taking a lead by demonstrating clear commitment and funding to the target.

16. The major landowning voluntary bodies (National Trust, Royal Society for the Protection of Birds and The Wildlife Trusts) own or manage more than 10% by area of SSSIs in England. Current figures show that something in the region of 68% by area of these sites is in favourable condition. We believe that the voluntary sector bodies have made a serious undertaking to help meet the Government's SSSI target and are making good progress in working towards achieving it.

17. The status of sites owned or managed by The Wildlife Trusts shows that approximately 80% are in favourable condition and that we are well on the way to achieving the 95% target. Much of this good work has been achieved with the generous support of the Heritage Lottery Fund and English Nature's Reserves Enhancement Scheme that is targeted to management of SSSIs.

18. We believe that Government should recognise the progress that has been made and the continued effort that is required for voluntary organisations to not only bring sites into favourable condition, but to maintain this status. We believe that ongoing support mechanisms are required for voluntary bodies like The Wildlife Trusts to manage our sites and that this represents real value for money. We would like to ensure that within the current review of Defra that funding to the voluntary sector for ongoing maintenance of sites in favourable condition in addition to support to bring additional sites to this status is not lost.

19. Approximately half of the SSSIs by area in England are under ownership or management of individual landowners or relatively small bodies. Progress against the target by this group shows that performance is behind the national average of 58% in favourable condition. However, The Wildlife Trusts believe that much good work is being done with this group, particularly as a result of the amendments to the Wildlife and Countryside Act 1981 (through the Countryside and Rights of Way Act 2000) which provided increased powers for the protection and enhancement of SSSIs. We particularly welcome the increased powers to enter into management agreements to encourage positive management of sites and strengthening of measures to protect sites by increasing penalties and closing loopholes that previously resulted in significant damage and destruction.

20. If this good work is to continue and progress against the target for smaller landowners is to be improved, it will be necessary to increase the funding available to English Nature for SSSIs and ensure better targeting of agri-environment schemes to these sites.

MAJOR FACTORS CAUSING UNFAVOURABLE CONDITION

21. The results of English Nature's condition assessment process show that many of the small scale issues causing unfavourable condition of SSSIs have been addressed, or can be influenced relatively easily through management advice and support. The real test for the collective commitment to the SSSI target comes with the major policy blockages that are largely outside the control of an individual landowner and can only be dealt with by major legislation, policy or funding changes across Government. These blockages are factors such as grazing, moor burning, coastal management and freshwater quality/quantity.

22. The Wildlife Trusts believe that Government must show genuine joined-up policy to deal with these issues and that by addressing relatively few key policy changes there could be a significant improvement in the target. The key issues that must be urgently addressed are:

— Effective targeting of agri-environment schemes to SSSIs and adjacent land, with farm payments conditional on appropriate grazing.

— Revision of the heather moorland and grass burning code and measures to support compliance.

— A review of commons legislation and support to encourage appropriate grazing in the lowlands through initiatives such as the Grazing Animals Project.

— A commitment to managed realignment of coastal areas within the context of shoreline management plans.

— Strategic and comprehensive measures (including regulatory measures) to address diffuse pollution together with an appropriate investment programme under AMP4 for freshwater and wetland sites, within the context of the Water Framework Directive.

23. We should also be putting strategies in place now to address climate change if we are to maintain favourable condition of sites in the long term.

24. The Wildlife Trusts believe that with more than 40% of sites still failing to meet the target there is still a long way to go to reach the 95% figure. It is also likely that the closer we get to the target, the harder it will become to tackle the issues impacting on unfavourable condition.

25. Government therefore needs to focus its effort on these key policy blockages and show real resolution in dealing with them. These should be integrated into the work programme of existing policy groups, in particular the Implementation Groups of the England Biodiversity Strategy, so that priorities are integrated and addressed.

THE ROLE OF DEFRA

26. The Wildlife Trusts welcome the pro-active role taken by Defra in establishing a "Major Landowners Group" to help coordinate delivery of the SSSI target. We believe this group has the potential to not only report on progress and share best practice in working towards the target but, more importantly, to identify and help resolve many of the policy blockages that are keeping sites in unfavourable condition.

27. In this respect we believe that Defra plays a crucial role in sharing ownership and commitment to this target, not only amongst the members of the Major Landowners Group but also amongst the cross-departmental "High Level Group" that has been established. The Wildlife Trusts are concerned that biodiversity issues including SSSIs are seen as solely the responsibility of Defra rather than being something that all Government departments and agencies contribute to under their duty to "have regard for the conservation of biodiversity".[21]

28. The Wildlife Trusts believe that the "High Level Group" provides an opportunity for all appropriate Government Departments and agencies to demonstrate their commitment to meeting the SSSI target and show their contribution to addressing the key policy blockages. In addition, it provides opportunities for new policy areas to be developed that make a positive contribution to this target.

29. In the current Defra Modernisation of Rural Delivery process there is a clear role for Defra and its agencies to ensure commitment to and delivery of biodiversity targets (such as the SSSI target) across Government. In order to do this, The Wildlife Trusts believe that the new proposed "Integrated Agency" should have:

— Biodiversity and natural resource protection as its primary statutory responsibilities.

— "Protection, conservation and enhancement of biodiversity" within its mission.

— An advisory role on biodiversity across the whole of Government.

— An independent scrutiny role across Government.

— A strong enforcement function.

30. We also believe that at the regional level the protection, conservation and enhancement of our natural heritage need to be better recognised with improved resourcing, structures and procedures for biodiversity. To be able to promote a sustainable development agenda The Wildlife Trusts believes the terms of reference of the Regional Development Agencies need to be amended and/or there needs to be other mechanisms to counterbalance the primarily economic focus of the RDAs, and to promote the conservation of the environment. This will include clarifying the role of new or existing environmental agencies at the regional level and developing regional environmental work programmes/strategies. This is essential if the activities of regional bodies are to contribute to rather than conflict with work towards the SSSI target.

31. Further recommendations on Modernisation of Rural Delivery can be found in the attached paper on biodiversity conservation in England. [22]

WIDER UNDERSTANDING AND ENGAGEMENT IN THE TARGET

32. The Wildlife Trusts believe that SSSIs can also play an important role in public understanding and involvement with wildlife. Our work has shown that such contact with nature can greatly contribute to quality of life and help to change attitudes and behaviour to the environment. We believe that Defra and its agencies should do more across Government and by building capacity within the voluntary nature conservation bodies to assist in engaging people in biodiversity. This could greatly assist in raising the level of concern and commitment to the SSSI target amongst the general public.

33. Research has also shown that biodiversity and the natural environment can have a significant positive impact on the local economy and social issues such as health and education. [23]The Wildlife Trusts believe that greater recognition of this contribution within those relevant Government departments and agencies is needed to increase commitment to the SSSI target.

Annex 1

REFERENCES

Publications

The Countryside and Rights of Way Act 2000, HMSO 2000.

The Environmental Economy of the West Midlands, Advantage West Midlands and the Environment Agency 2001.

Working with the Grain of Nature—a Biodiversity Strategy for England, Defra 2002

Measuring Progress—Baseline Assessment, Defra 2003.

England's Best Wildlife and Geological Sites—the condition of Sites of Special Scientific Interest in England in 2003, English Nature 2003.

16 March 2004