Memorandum submitted by the National Trust
(N20)
1. The National Trust welcomes this opportunity
to contribute to the Committee's inquiry into progress towards
achieving Defra's Public Service Agreement (PSA) target that by
2010 95% of all nationally important wildlife sites should be
in "favourable condition".
2. The National Trust is the owner of the
third largest SSSI (Site of Special Scientific Interest) estate
in England, after the Ministry of Defence and the Forestry Commission.
Of the Trust's 245,000 ha land 25% is SSSI, that part in England
amounting to 6% of the England SSSI component.
SUMMARY
3. Biodiversity and geodiversity are fundamental
components of our environment, providing a wide range of essential
resources and services, including clean air and water, good health,
cultural inspiration and enjoyment. SSSIs are a representative
sample of the best of the nation's bio- and geodiversity. The
health of these wildlife and geological sites is, therefore, an
important indicator of the nation's progress towards achieving
sustainable development and improving people's quality of life.
4. The Trust supports the Government's target
to have 95% of its SSSI network in favourable or recovering condition
by 2010. It is a demanding but sensible challenge and a measure
of the Government's contribution to the UN World Summit on Sustainable
Development commitment to reducing the rate of biodiversity loss
by 2010.
5. The target is important and should remain
to raise the profile of the England's biological and geological
resources, to focus public funding and resources, to attract private
investment, to provide a common goal for a wide variety of organisations
to work together and to strengthen the leadership roles of English
Nature and of the new Integrated Agency, once established. It
also provides an important tool to help the Government avoid the
possibility of infraction proceedings from the European Court
for not ensuring the favourable conservation status of England's
Natura 2000 sites.
6. English Nature has a vital role in ensuring
the target is met, but it acts principally as a champion, catalyst,
enforcer and facilitator. As the lead delivering agent English
Nature (and in future the Integrated Agency) will need to be fully
resourced to properly assess SSSIs, advise land managers of the
management, establish Management Agreements, monitor progress
and enforce where necessary.
7. Delivery of favourable condition across
England's SSSIs will come through partnerships, usually directly
with land owners and land managers, which need to be supported
by a range of incentives and advice, backed by effective standards
and regulation, and operating within a supportive policy framework.
This does not yet exist.
8. The initial analysis of the National
Trust's SSSIs largely reflects the overall national pattern, with
our lowland sites in better condition than average and our upland
sites in slightly worse condition—many because they are
common land and have either too many rights of common being exercised
or too few for the conservation of the ecological interest to
be sustained.
9. Our analysis is that the main land management
changes needed to achieve the PSA target in the short term are:
— reducing the intensity of sheep grazing
in the upland habitats (and a more appropriate sheep and cattle
mix);
— increasing livestock (sheep and cattle)
grazing the lowland habitats;
— a reduction in the direct and diffuse
pollution burdens affecting all habitats, especially the freshwaters;
and
— an ambitious programme of realignment
of our coastline to provide space for the coastal habitats to
adapt to sea level rise.
10. Defra is in a dynamic and creative period
of policy-making that could provide significant opportunities
for a step-change in securing positive land management changes
to improve the condition of England's SSSIs as well as the wider
countryside. The Government will need to be bolder and more innovative
in using the tools available to move towards sustainable land
management and to improve the long term prospects for England's
wildlife and geology. In particular, the Trust is looking for:
— Sufficient incentives—a switch
of direct farm payments (modulating at least 10% CAP payments)
to fund the new agri-environment programme.
— Integrated advice—a farm/land
manager advisory service, to raise awareness and develop skills,
to put the environment at the heart of the farm business and to
promote collaboration between land managers and owners.
— Minimum environmental standards—robust
and enforced cross compliance on the Single Farm Payment, especially
to control the worst of the overgrazing in the uplands and diffuse
pollution.
— A diffuse water pollution strategy—with
new measures to tackle diffuse water pollution from agriculture,
including small-scale capital grants.
— New legislation—to modernise
the legal framework for common land to improve governance and
the long term collective management of commons.
11. This demonstrates the need for the committee
to focus its attention on the broad regulatory, fiscal and policy
environment within which landowners and managers operate if SSSIs
are to be further improved.
12. Looking ahead, our philosophy and approach
to SSSI management needs to evolve to focus as much beyond the
site boundary as within it. Improving the condition of SSSIs cannot
be achieved in isolation from the wider environment, particularly
if wildlife is to adapt to climate change. For that we need a
landscape-scale approach to the conservation of our biological
and geological resources. Working at this scale requires a substantial
shift in behaviour and approach of policy makers and delivery
bodies and far greater collaboration between land managers and
owners. Such action should be more cost-effective in the long
term and provide multiple benefits when compared to issue-specific
action aimed at redressing the damage done internally to one site
only. We urge the Committee to identify this as a key task for
Defra and the new Integrated Agency.
NATIONAL TRUST
PROGRESS ON
SSSIS
13. The National Trust owns and manages
63,700 ha of SSSI across 2,153 units in England. The Trust's SSSIs
range in size and habitat, from the smallest ponds at Stockbridge
Common on the Isle of Wight to the expanse of upland bog of The
Dark Peak in the Peak District. By July 2003 34,531ha (55%) of
the SSSI component had been assessed by English Nature (EN) as
being in favourable or recovering condition and 28,418ha (45%)
in unfavourable no change or declining condition.
14. On Trust SSSI, the dry lowland habitats
are approaching the desired state and are generally ahead of the
national picture (range 78-98% meeting the PSA target). Coastal
habitats, similarly, are generally in healthy condition (78-100%).
Freshwater habitats are only marginally more in favourable condition
than not (58-62%). And the upland habitats are variously in poor,
moderate and good condition (5-91%). See Fig 1.
15. The most important factors affecting
the National Trust's SSSIs, by a combination of area and habitat
affected (but in no order), are scrub invasion, undergrazing,
overgrazing, direct and diffuse pollution, coastal squeeze, water
abstraction (see Fig 2). Many sites are affected by more than
one issue (such as overgrazing and diffuse pollution, or scrub
invasion and undergrazing). Deer browsing and inappropriate woodland
management are important factors in the woodland habitats but
affect only a small area of land.
16. The biggest areas of failing land are
in the uplands: calcareous upland grassland (5,385 ha), upland
dwarf shrub heath (7,724 ha) and bogs (8,679 ha). These three
habitats comprise nearly 50% of the Trust's SSSI holding.
17. In the uplands, the major problem preventing
a recovery to favourable condition is overgrazing (prime cause
of failure on 61% of the 23,768 ha failing in the uplands), usually
as a result of stocking rates maintained artificially high by
agricultural subsidies. This is further complicated in the Peak
District by a long history of air pollution, where fragile bog
habitats have been badly affected and the residual effects could
take decades to repair. Woodland overgrazing, by contrast, is
a result of stockshelter or the presence of deer.
18. In the dry lowland habitats, scrub invasion
and undergrazing are the most significant issues, affecting 61%
of the 1,635 ha of lowland habitats not meeting the PSA target.
Conversely, there are often too many deer in the lowlands: deer
browsing of coppice regrowth and natural regeneration is a particular
problem in woodlands in these areas.
19. In the wetlands, direct and diffuse
waterborne pollution is a significant problem as well as abstraction.
20. Small areas of land failing to meet
the target can be as significantly important to some habitats
(eg inshore sublittoral sediment) as large areas are to others
(eg bogs).
21. The Trust is committed to working in
partnership with a wide range of organisations, from statutory
agencies and voluntary bodies to neighbouring land owners. The
Trust is a member of the Major Landowners Group, which has been
established by Defra to help achieve the target and as a landowner
and manager, the National Trust values the working relationship
that has been established between the Trust and English Nature
(and other agencies such as the Environment Agency), at a national
and local level.
Note: data for both figures has
been extracted from that supplied to the National Trust by English
Nature in July 2003.
CHANGES NEEDED
TO MEET
THE TARGET
22. We identify the following measures as
critical for delivering the changes that are required if the SSSI
PSA target is to be met.
Incentives
23. The most important and immediately effective
mechanism for delivering the PSA target by 2010 will be the new
England agri-environment programme. The Entry Level Scheme (ELS)
will be available to every farmer, which will set an important
foundation of good land management. However, in most cases, the
ELS will be too modest to effect significant changes to the management
of SSSIs that need urgent attention. It is therefore essential
that the Higher Level Scheme (HLS) has sufficient funds, capacity
and flexibility to target SSSI management effectively, on an area
basis as well as farm by farm.
24. We urge the Government to make maximum
use of the opportunity to switch CAP funds from direct Single
Farm Payment to invest in the new agri-environment programme through
modulation. This will help to ensure that public money is spent
wherever possible on more sustainable land management and to demonstrate
the Government's commitment to meeting its PSA target.
25. The new agri-environment programme also
provides an important strategic mechanism to both buffer SSSIs
and "Defragment" the countryside. To help tackle the
root causes of, for example, lowland undergrazing or habitat restoration,
the programme will need to have robust processses for local and
regional targeting. Areas and farms with SSSIs in unfavourable
condition should be a priority for the new programme and managers
of the land surrounding the SSSI should also be targeted for entry
into the HLS, especially where this strategically reconnects habitats.
26. Links between upland and lowland livestock
producers are important for the future viability of farms, as
well as sustaining conservation grazing of SSSI. As English Nature's
Wildlife Enhancement Scheme (WES) is due to end in 2005, we suggest
a pilot scheme (linked to the agri-environment programme) is established
to link upland SSSI livestock farmers with lowland SSSI livestock
"finishers". The Grazing Animals Project (GAP) could
run the pilot, as they have led successful partnership work on
conservation grazing.
Advice
27. Farmers are facing a scale and pace
of change unseen for the last 50 years. They need to be able to
adapt and respond successfully during this transition, and information,
support and advice is critical. Following the recommendations
of the Curry Commission in 2001 and Lord Haskins in 2003, there
is an urgent need for an integrated environment and business advisory
service for farmers and land managers which puts the environment
back into the heart of the farm business. This should include
training and advice for managers of SSSIs, not only on the sensitive
land management practices required but also on how this can be
integrated with the operation of a successful rural enterprise.
28. Facilitation is also needed to broker
more collaborative land management agreements, so that SSSIs and
their surrounding areas are managed as a whole, rather than discrete
units. Greater partnership working between landowners is needed,
but the real difference is made through farmer/land manager collaboration,
particularly if we are to secure economic benefits as well as
land management benefits.
29. A farm/land manager advisory service
is critical, especially where, as in the case of the National
Trust, a large proportion of SSSIs are managed by tenant farmers,
often with Agriculture Holdings Act tenancies (ie without the
right for landowners to insist on the inclusion of nature conservation
clauses), and commoners. In these cases management agreements
aimed at achieving a recovery to favourable condition often have
to be negotiated directly between the responsible agency and the
tenant or common rights holders.
30. The Trust has invested hugely in developing
its own integrated business and environmental advisory service
for its farm tenants. A network of 16 farm and countryside advisers
is at the forefront of delivering our whole farm planning programme.
The advisers are able to draw on specialist nature conservation,
environmental, archaeology and rural business expertise to ensure
that an integrated approach is taken to solving environmental
problems across farms and beyond the farmgate. In our experience
it is an approach that works and there needs to be a similarly
holistic investment in service provision to farmers and land managers
country-side as part of the delivery of the new agri-environment
programme, wider CAP reform and the government's strategy for
sustainable farming and food.
Minimum Standards
31. For the first time, environmental conditions
will be attached to direct (CAP) farm payments from 2005, so called
cross compliance. This gives the Government scope to raise the
baseline performance of all farms and ensure public benefits are
secured from farm payments. The conditions set must be meaningful
in changing the behaviour of land managers and properly enforced.
There is a real chance to tackle some of the damaging practices
which chronically affect SSSIs at farm level, whether it be slurry
leakage, soil erosion, pesticide use or cutting of hedgerows.
A whole farm audit should be a critical component of cross compliance
and this will help to identify environmental risks to SSSIs.
32. The Government has recognised the lack
of policies and delivery tools to tackle diffuse water pollution
from agriculture (DWPA) and undertaken a wide-ranging review.
We look forward to Defra publishing its DWPA report and action
plan as soon as possible. One of the missing tools to address
the root cause of farm pollution is the lack of small capital
grant schemes for dealing with organic and other farm wastes,
soil and water management, as these issues consistently come out
as high priorities from the Trust's whole farm action plans.
Legislation—Common Land
33. One of the most significant factors
in the overgrazing of the upland SSSI habitats (such as in the
Lake District fells) and the undergrazing of many lowland SSSI
habitats (such as in the Surrey heaths) is that they lie on areas
of common land. Despite the intention of the Commons Registrations
Act 1965, these areas are still beset by confusing rights issues,
uncertainties over collective and individual responsibilities
and, in the uplands, insufficient resources to meet the demands
of the rights holders. The major problem in the lowlands is the
lack of livestock-owning rights-holders able to exercise their
rights, although increasing public use, restrictions on erecting
fences to enable management schemes to be put in place and the
walking of dogs off their leads are also problems.
34. The National Trust owns 66,000 hectares
of common land in England and Wales—41,500 ha in England
(11% of common land in England)—comprising 25% of the Trust's
estate.
35. The Trust believes that new legislation
is urgently required for common land to achieve the SSSI PSA target.
Until we have an effective legal framework which enables better
governance and long term collective management of commons, we
will continue to see overgrazing in the uplands and undergrazing
in the lowlands and the most intractable issues in SSSI management
will not be addressed.
36. The new framework should enable individual
or multiple rights-holders, or indeed the landowner, to reduce
the exercising of their rights without disadvantage where over-use
is preventing "favourable condition" or to allow new
management or exercising of unused rights where under-use is the
problem. It will also be important to protect the rights and duties
of the landowner, who may have specific responsibilities for management
of the site or aspirations which differ from those of the rights-holders.
37. The Trust's priorities for legislation
are:
— statutory associations which should
include the landowners, those holders of rights other than grazing
and representation of other public interests;
— a live register, working to known
numbers of grazing animals;
— enabling the deregistration and extinguishment
of rights to be handled fairly; and
— dealing comprehensively with wrongly
registered rights, particularly on commons with excessive numbers
of livestock.
38. The Trust also believes the phrase "sustainable
agricultural management" which underpins delivery of common
land management is too narrow, omitting important public benefits
such as nature conservation and landscape. It is important, therefore,
to find a solution for managing the collective interests of individual
commoners in a way that provides for public interests and enjoyment
of an accessible common which is in good ecological and landscape
condition.
Wider policy frameworks
39. The SSSI PSA target is also affected
by a large number of other policies and the Government needs to
be as creative as possible in optimising these opportunities.
For example, the Periodic Review and Asset Management Programmes
(AMP) of the Water Companies should help to tackle many sewage
discharge and water abstraction impacts on SSSIs. Equally, a strong
and effective land use planning system is key to preventing destruction
and damage from new development.
40. Full advantage should be taken by all
parties of the opportunities provided by the forthcoming implementation
of the Water Framework Directive to help achieve the target for
aquatic habitats such as ponds and rivers. The WFD will provide
an important planning tool at a catchment scale to help reduce
diffuse pollution, secure better soil management and restore damaged
or constrained rivers.
41. The England Rural Development Programme,
implemented at the regional level, provides a real chance to stimulate
activities that support the managers of SSSIs, by providing local
economic value from a high quality environment, through local
food, tourism and other enterprise initiatives. Regional Development
Agencies will have a key role in investing in local economies
and their Regional Economic Strategies should embrace the SSSI
PSA target as protecting an essential economic as well as environmental
resource.
AN EVOLVING
PHILOSOPHY AND
APPROACH
42. Improving the condition of SSSIs will
not be achieved sustainably in isolation from the wider environment.
The biodiversity in SSSIs is recharged and often sustained by
areas outside of the site, areas which provide supporting populations
of species or supplementary foraging. In the same way, detrimental
factors arising externally to the site, such as edge effects of
urban development or diffuse pollution can affect the biodiversity
within.
43. The external pressures on SSSIs will
continue and will probably exacerbate the problems of site-based
approaches to the management of SSSIs. We are already witnessing
problems with coastal habitats being damaged and destroyed by
the squeezing effect of a rising sea level towards hard sea walls.
The rate of realignment of the coastline and coastal defences
needs to be significantly increased to provide sufficient space
for the re-creation of the coastal habitats which are currently
continually lost to erosion and sea level rise.
44. A new philosophy and approach is required,
both to the way in which decision-makers think and also the way
in which practitioners deliver, especially if we are to help the
environment adapt to climate change and other pressures. We need
to move towards a landscape scale approach that seeks to reconnect
fragmented habitats, including SSSIs, in order to gain greater
ecosystem resilience, capacity and functionality. This much wider
spatial and longer term approach requires a substantial shift
in behaviour and approach of policy makers and delivery bodies
and far greater collaboration between land managers and owners.
We urge the Committee to identify this as a key priority for the
new Integrated Agency and for Defra.
45. In the longer term, the investment required
to bring 95% of England's SSSIs into favourable or recovering
condition by 2010 will only have been worth it if those in favourable
condition remain so and those which are recovering actually reach
truly favourable condition. For some of those recovering sites
it could be decades before they attain that favourable condition.
The importance of persistent funding, both to change unfavourable
and also to maintain favourable sites post 2010 should not be
underestimated.
46. However, adopting a more sustainable
approach to land management across the whole of England will be
the most cost-effective way of dealing with the legacy of long-term
decline and to maintain health and recovery of England's SSSI
network in the future.
22 March 2004
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