Memorandum submitted by The Wildlife Trusts
(V04)
INTRODUCTION
1. The Wildlife Trusts welcome the opportunity
to submit evidence to the Environment, Food and Rural Affairs
Committee on the Government's Rural Strategy 2004.
2. The Wildlife Trusts are a unique partnership
of 47 local Wildlife Trusts covering the whole of the UK, the
Isle of Man, The Scilly Isles and Alderney. The partnership campaigns
for the protection of wildlife and invests in the future by helping
people of all ages to gain a greater appreciation and understanding
of nature. Collectively The Wildlife Trusts have 560,000 members
and manage almost 2,500 nature reserves, covering more than 80,000
hectares of land, ranging from inner city urban sites to the UK's
finest wildlife areas.
3. The Wildlife Trusts not only play a leading
role in advocating the cause of environmentally sustainable development
locally, regionally and nationally, but they are also expert in
the delivery of practical sustainable development projects around
the United Kingdom. The Wildlife Trusts' unique knowledge of the
natural environment and biodiversity resource of this country
combine well with their strong local partnerships to allow them
to make links across the "silos" and to demonstrate
how the natural environment can contribute to the achievement
of social and economic objectives.
4. The Wildlife Trusts hold passionate opinions
on the future of the Integrated Agency and the proposed changes
to the funding streams. Our knowledge and understanding of the
threats and opportunities that face wildlife across this country
is second to none and as such The Wildlife Trusts believe they
have a firm mandate for their policies.
AN INDEPENDENT
INTEGRATED AGENCY
5. For more than 60 years, The Wildlife
Trusts have been an advocate for a strong agency able to give
independent advice to Government on the extent and nature of our
biodiversity and the ways it should be protected, conserved and
enhanced for people's use and enjoyment. This is important not
just for people today but for future generations. The Wildlife
Trusts support goes back to before the establishment of the first
such agency—the Nature Conservancy—in 1947 and has
continued throughout the various manifestations of this organisation
ever since.
6. This support is not born out of nostalgia
for the past but rather out of a strong conviction that a matter
such as the protection, conservation and management of our biological
natural resources is central to this country's economic, social
and environmental well-being. Our environmental wealth is as significant
as our social and economic wealth and indeed contributes a great
deal to it. The issues that determine and influence our environmental
wealth need to be weighed carefully by Government with other considerations
and deserve at least equal consideration as social and economic
matters.
7. The Wildlife Trusts welcome the establishment
of the new Integrated Agency with the opportunity it provides
to integrate policy and practice across a wide swathe of environmental
issues affecting our countryside, urban, coastal and marine environment.
The new Integrated Agency has the potential to address a central
concern of the original Rural White Paper—the clarification
of "the linkages between the environment and social and economic
activity". The White Paper went on "there is still a
long way to go until the environmental concerns are fully integrated
into wider social and economic rural policy agendas (and vice
versa)". The Integrated Agency could be a key player in catalysing
activity on this important issue.
8. The voluntary sector, and The Wildlife
Trusts in particular, are leading the way here, working with business,
farmers and local communities on the ground to demonstrate the
contribution the natural environment makes to the economy. The
Integrated Agency should recognise this and should invest in the
voluntary sector to build not only on innovative schemes but also
on the huge added value there could be from engagement with these
bodies in the voluntary sector that are already integrated into
communities.
9. The Wildlife Trusts were encouraged by
the Secretary of State's promise that the new Integrated Agency
will be a "powerful, independent statutory Non-Departmental
Public Body building on the world-class strengths of English Nature,
the Countryside Agency and the Rural Development Service".
This country has been able to show leadership and deliver domestically
due in part to our strong and effective agencies, working with
a strong voluntary sector.
10. It is vital that while promoting integration
the new agency retains the duty not only to promote and enhance
biodiversity but also a specific duty to "protect and conserve"
it too. One test of this will be the retention of the existing
duties enshrined in law and, in particular the requirements in
the Wildlife & Countryside Act 1981 (as revised by the Countryside
& Rights of Way Act 2000) in an unaltered or strengthened
state. A second test will be a continuing commitment to implementing
our international obligations, for example, under the Convention
on Biological Diversity and a retention of current Government
targets, for example, environmental Public Service Agreements
(PSAs) and targets in the Government's UK Biodiversity Action
Plan. A third test will be the agency's ability to protect and
manage important local sites outside the SSSI system. Local Site
systems are in place nationwide but need more Government support.
Local Sites are increasingly important as reservoirs and "stepping
stones" for wildlife at a time when the countryside must
be able to adapt to the effects of climate change and are essential
if the Government is to effectively deliver its rural strategy.
THE AGENCY'S
BIODIVERSITY FUNCTIONS
WITHIN A
SUSTAINABLE DEVELOPMENT
CONTEXT
11. A central plank of Government policy
is for development to be sustainable. To achieve a sustainable
development process that ensures the integration of environmental
issues with economic and social considerations requires the environment
to have a stronger voice than at present to counter-balance and
inform economic arguments that until now have tended to dominate
decision-making.
12. For this reason, well-informed and timely
advice must continue to be available to Government on the environment
generally and on biodiversity in particular. The new agency must
remain a champion for biodiversity giving independent advice to
Government on our biodiversity resource and how it should be managed
to conserve and enhance it for the future. While this advice needs
to be in a form that will assist in decisions about how economic
and social policy can be sustainable, the Agency should not be
singled out as a body that must temper its opinions at the earliest
stage in order to bend to priorities emerging elsewhere.
13. The Wildlife Trusts believe the Committee
should therefore explore further what is meant by the Secretary
of State's reference in her July statement that the Integrated
Agency will have a remit to carry out its functions "within
a sustainable development context". If this is to be on the
face of legislation or in formal policy advice, similar wording
should be applied across all Government Departments and NDPBs.
Indeed, the Integrated Agency is probably the last body likely
to do anything but fight to ensure that we do not compromise the
ability of future generations to meet their own needs which is
in our opinion the definition of sustainable development.
14. What does sustainable development mean
to society, to Government and for Government policy? In its recent
consultation document Taking it on the Government recognises that
there are different views on how best to describe what it means
and no clear vision of what it might look like in practice for
the UK. The Wildlife Trusts believe it would therefore be prudent
not to include reference to sustainable development in any new
law to establish the new Integrated Agency until these issues
are clarified further.
THE SCOPE
OF THE
INTEGRATED AGENCY
15. The Wildlife Trusts welcome the fact
that the new Integrated Agency will have responsibility for resource
management and will take an integrated approach to enhancing the
natural environment and our enjoyment of it across rural, urban,
marine and coastal England. This raises three particular issues.
First, there will need to be close collaboration between agencies
outside the new family, in particular the Environment Agency and
the Forestry Commission. Second, the new agency must retain expertise
and a capability to deliver in the urban environment.
16. Third, The Wildlife Trusts are deeply
involved with discussions about the future protection and management
of the marine environment. As part of Wildlife & Countryside
Link's campaign for a comprehensive package of marine legislation,
The Wildlife Trusts believe that a systematic and co-ordinated
approach is required to the governance of the sea to protect our
biological and cultural heritage and better manage marine resources.
17. The emerging new Integrated Agency,
the Environment Agency and those involved in developing the thinking
and policy on the "governance of the sea" will all need
to contribute to the discussions on future arrangements for managing
the marine environment. It will be necessary to maintain full
and open dialogue between each of these organisations to ensure
that they do not "trip over one another" as policy on
this sector is developed.
THE REGIONAL
DIMENSION
18. The Wildlife Trusts' views are set out
against the background that Government Guidance in 1998 identified
a clear sustainable development agenda for Regional Assemblies
based on environmental, social and economic benefits. In practice
there has been minimal investment in the environmental angle of
this responsibility and the environmental voice at the regional
level has been weak in comparison to the economic and social sectors.
The current review of modernising rural delivery represents an
opportunity to address this situation.
19. The Government's rural policy should
on occasions, take precedence over, short term economic objectives
if overall sustainable development objectives are to be met. Indeed
the advancement of social issues and economic development often
depend upon a high quality environment as illustrated by the series
of Environmental Economy Reports published at a regional level
in most English regions. To be able to promote a sustainable development
agenda The Wildlife Trusts believe that the role of new or existing
environmental agencies at the regional level and developing regional
environmental work programmes/strategies will need clarifying
and strengthening. Regional strategies need to take account of
the regional chapters of the England Rural Development Programme,
regional spatial strategies, and the need to achieve rural regeneration
as well as regional biodiversity objectives.
20. The terms of reference of the RDAs may
need to be amended and/or there need to be other mechanisms to
counterbalance the pure economic focus of the RDAs and to promote
the conservation of the environment. The Wildlife Trusts shared
the concerns expressed in paragraphs 5.7-5.9 of Lord Haskins'
Rural Delivery Review. While accepting that RDAs should have a
key role in delivering DEFRA's rural economic and social agenda,
The Wildlife Trusts believe that because their primary aim is
co-ordinating regional economic development and regeneration it
is not possible, in the current circumstances, for them to fulfil
a broader environmental role. With their existing terms of reference
of "contributing to sustainable development, where it is
relevant to do so, as part of their wider economic duties"
they cannot take a balanced view of environmental issues. Haskins
himself says in his Review (paragraph 5.2) "they must demonstrate
that they are ready to assume new responsibilities". In the
view of The Wildlife Trusts, to achieve this, they will need to
bring in environmental expertise from external sources and operate
in close consultation with external stakeholders.
21. Regional governance for biodiversity
and the environment is currently poorly resourced leading to a
weak voice for the natural environment in comparison with the
other main strands of Government policy. The protection, conservation
and enhancement of our natural heritage need to be better recognised
at the regional level with improved resourcing, structures and
procedures for biodiversity. The current governance deficit can
be aided by providing regional leadership supported by clear joint
regional programmes that can be scrutinised to assess progress.
The Wildlife Trusts would welcome more statutory weight being
attached to joint regional environmental priorities that have
been identified. These will need adequate scrutiny procedures
(probably via the Regional Assemblies).
22. Any new arrangements at the regional
level must:
— enable regional areas to deliver
national and regional priorities efficiently; and
— ensure that clearer statutory duties
are placed on all those operating at the regional level to protect,
conserve and enhance our natural heritage.
23. In view of this The Wildlife Trusts
believe:
— Regional environmental and biodiversity
strategies must be given teeth—elements should be statutory
rather than acting as guidelines or frameworks. The Regional Assemblies
should set themselves regional environmental PSA targets and success
with achieving these should be scrutinised by central Government.
Regional Environmental Strategies and programmes should be prepared
by regional stakeholders and revised within an appropriate cycle.
Regional Environmental Strategies should inform the Regional Economic
and Social Strategies to lead to a genuinely integrated Strategy
that can be delivered through the Regional Spatial Strategy.
— Regional Development Agencies should
remain as economic bodies integrating natural resource protection
within their plans and programmes and delivering natural environmental
benefits, not least because this will assist the economy. Given
the current strengths of the RDAs and their significant impact
on the environment the opportunity should be taken to ensure that
RDAs demonstrate how they are adhering to the biodiversity requirements
of the CROW Act 2000 (Section 74) and European environmental legislation.
RDAs should have a duty to integrate natural resource protection
within their plans and programmes and deliver development that
is truly environmentally sustainable using transparent sustainability
appraisal at all stages of decision-making.
— The new Integrated Agency should
have a strong statutorily based and well-resourced regional structure
which should take an active and dynamic approach to engaging with
regional stakeholders to frame the Regional Environmental Strategy
and influence other regional decision making processes.
— The concern is that the environmental
sector (eg regional staff of the new Integrated Agency and the
budget at the disposal of the Regional Assembly) will remain under-resourced.
As a result the sector will find it difficult to play a full role
in policy development and delivery in the regions. More resources
will be needed if the new Integrated Agency is to have teeth regionally.
If more resources do not become available a focus of existing
resources at the regional level must be considered.
16 September 2004
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