Select Committee on Environment, Food and Rural Affairs Written Evidence


Memorandum submitted by the Bat Conservation Trust (DAR 10)

EXECUTIVE SUMMARY

  1.  Thank you for inviting the Bat Conservation Trust to give evidence to the EFRA Committee's inquiry into Defra's Departmental Report 2006 and Defra's budget, in particular the impact of Defra's 2006-07 budget cuts on our organisation's work.

  2.  The Bat Conservation Trust is the only organisation concerned solely with the conservation of bats within the UK. It is a registered charity, serves a network of over 95 bat groups across the UK, and has a membership of over 4,000. We are supported in our work by government agencies, professionals and volunteer bat workers. BCT is Lead Partner for UK Species Action Plans for five of the UK's 17 bat species and is actively involved in promoting species conservation legislation and policy at European, national and local levels.

  3.  BCT receives funding from Defra and its related agencies for a wide range of high priority bat conservation services, many of which are excellent examples of third sector delivery. These services include: action for BAP priority bats, volunteer development for statutory advice provision, monitoring of population trends for BAP reporting and conservation status assessment, management of rabies risk through bat helpline provision, and delivery of European commitments.

  4.  This financial year cuts to Defra's budget, and corresponding impacts on the budgets of Natural England and the JNCC, have resulted in great uncertainty and high risk to BCT with regard to continuation of species monitoring on designated sites, the future of the National Bat Monitoring Programme, training course provision and rabies risk management. The effects go far beyond BCT—affecting thousands of volunteers dedicated to bat conservation.

  5.  The cuts to Defra's budget have also had more general implications for bat conservation by affecting the implementation and interpretation of amended protected species legislation, delaying the development and provision of much needed standardised guidance, and lack of knowledge of mitigation effectiveness due to under-monitoring of development licences.

  6.  BCT understands that Defra funding cannot be limitless. However, given continuing cuts and an environment of short-term prioritisation and uncertainty, BCT is not able to collaborate effectively with related agencies to produce cost effective strategic solutions for the long term.

  7.  A joined up approach between Defra's agencies and also other government departments that impact biodiversity, for example DCLG, would give great potential to deliver not only bat conservation, but conservation of all Britain's biodiversity, our natural heritage.

INTRODUCTION

  1.  Thank you for inviting the Bat Conservation Trust to give evidence to the EFRA Committee's inquiry into Defra's Departmental Report 2006 and Defra's budget, in particular the impact of Defra's 2006-07 budget cuts on our organisation's work.

  2.  The Bat Conservation Trust is the only organisation concerned solely with the conservation of bats within the UK. It is a registered charity, serves a network of over 95 bat groups across the UK, and has a membership of over 4,000. We are supported in our work by government agencies, professionals and volunteer bat workers. BCT is Lead Partner for UK Species Action Plans for five of the UK's 17 bat species and is actively involved in promoting species conservation legislation and policy at European, national and local levels.

OUR WORK WITH DEFRA AND ITS AGENCIES

  3.  BCT receives funding from Defra and its related agencies for a wide range of high priority bat conservation services, many of which are excellent examples of third sector delivery. These services include:

    3.1  Action for Biodiversity Action Plan (BAP) priority bats is a Natural England-funded programme to coordinate and deliver lead partner action and reporting for five priority species of UK bat. The BCT takes a landscape approach to delivery of the action plans and has produced good practice guidelines on a variety of priority areas eg guidelines for Woodland Managers (a partnership project by BCT funded jointly by Forestry Commission, English Nature and Countryside Council for Wales).

    3.2  Bat Group Development—Another aspect of the action programme funded by Natural England concerns bat group development, which delivers highly skilled volunteers who provide advice to householders about bats on behalf of the Statutory Nature Conservation Organisations.

    3.3  The National Bat Monitoring Programme delivers statistically defensible information about Britain's bats, which informs the review, reporting and target setting for the UK bat BAPs and the assessment of Favourable Conservation Status under the EU Habitats Directive. The NBMP is part funded by the JNCC.

    3.4  Bat Casework—BCT administers statutory bat casework for eight English areas on behalf of Natural England. This involves coordinating volunteers to make free roost visits to householders requiring advice about their bats in order to promote bat conservation and welfare and to fulfil Natural England's statutory requirement to provide advice where there is potential threat to bats.

    3.5  National Bat Helpline—The role of the Helpline Service has become even more important following the recent incidents of bats and rabies in the UK. The Helpline is a critical tool in ensuring that the public and batworkers have the most up to date guidelines on bats and rabies issues in order to manage and minimise the risk, a fact acknowledged by contributory funding from the Veterinary Laboratories Agency.

    3.6  Delivery of the UK's European commitments—Grants from the international subscriptions budget enables BCT to deliver and uphold aspects of the UK's commitment to the EUROBATS "Agreement on the Conservation of Populations of European Bats" on behalf of Defra, by meeting requirements of adopted resolutions. For example we have organised workshops on developing a pan-European monitoring programme and standardised monitoring guidelines; we delivered projects to share knowledge with colleagues in other European countries to build their capacity in bat conservation; and we coordinate activities relating to European Bat Weekend each year on behalf of the UK government.

DIRECT IMPLICATIONS OF DEFRA'S BUDGET CUTS ON BCT'S WORK

  4.  This financial year cuts to Defra's budget, and corresponding impacts on the budgets of Natural England and the JNCC, have resulted in great uncertainty and high risk to BCT with regard to continuation of species monitoring on designated sites, the future of the National Bat Monitoring Programme, training course provision and rabies risk management. The effects go far beyond BCT—affecting thousands of volunteers dedicated to bat conservation. These aspects are outlined in turn below:

    4.1  Designated sites monitoring—We deliver common standards monitoring for sites designated for greater horseshoe bat and barbastelle (both BAP priority species and Annex II Habitats Directive) on behalf of Natural England. We have a long history of working with the agencies. Our working relationship is based on trust and this financial year we once again commenced work on instruction from the agency before a contract was finalised. This year, however, for the first time we were told that the funding would not be forthcoming, as a direct result of the cuts. Rather than stop the volunteers from doing their work and thereby harm the robustness of long-term monitoring by missing a years worth of data we continued. This lead to substantial concern, increased uncertainty for volunteers on the ground, and heightened risk for BCT. We have only just been notified that following the release of funds to Natural England from Defra this high priority work will in fact be funded. We are worried that this has lead to volunteers feeling undervalued.

    4.2  Population trend monitoring—BCT runs the National Bat Monitoring Programme (NBMP) that delivers population trends for eleven of the UK's 17 bat species, including trends for four priority BAP species. These trends are used in BAP target setting and reporting and therefore also contribute to the BAP priority species status indicator that is used in judging progress on, for example, the England Biodiversity Strategy and the "2010 Target to Halt Biodiversity Loss". Species population trends from the NBMP are also being used by JNCC in making assessments of Favourable Conservation Status as required of the UK for reporting to the European Commission under the EU Habitats Directive. The programme is an acknowledged success delivering value for money, a clear partnership between volunteers, BCT and government. It is imperative that monitoring is long term and that the programme is developed to include additional species. Continuation and future expansion both depend on adequate resourcing of the programme. To date, the majority of funding has been met by the JNCC, however due to budget cuts and restricted funding JNCC can only part-fund the programme. The total programme costs £120,000 to run per annum and this financial year only £82,000 is funded. The lack of full cost recovery jeopardises the investment, not only of funds, but the volunteer investment. BCT is unsure as to the future of the programme. Please find attached a summary report of the NBMP "State of the UK's bats".[1]

    4.3  Training and public engagement—Our work to train and engage people is currently in jeopardy because of a shortfall in funding that was previously met by the biodiversity stream of the Environmental Action Fund (EAF). BCT delivers training to numerous sectors that impact bats and their conservation, such as arborists, planners, constructors and ecological consultants and surveyors. This training is an essential component of priority action for the BAP bats. The funding was transferred from Defra to EN Countdown 2010 Biodiversity Action Fund and BCT was informed that although the work is considered a priority, due to Defra cuts the project could no longer be supported. Please find attached our Training Brochure for 2007.[2]

    4.4  Rabies risk management—BCT has been notified that due to Defra funding cuts the full costs of this National Bat Helpline service in providing advice to the public and the bat worker community this year may not be covered and future funding is extremely uncertain. The European Bat Lyssavirus Group has acknowledged the outstanding value of the service.

IMPLICATIONS OF DEFRA'S BUDGET CUTS ON BAT CONSERVATION GENERALLY

  5.  The cuts to Defra's budget have also had more general implications for bat conservation including:

    5.6  Implementation of species protection legislation—We have great concern over Defra's apparent under-resourcing of the production of guidance to accompany the imminent changes to the Habitats Regulations. We realise that the legislation has to change in response to the ECJ ruling against the UK, however the potential problems this is likely to cause for bat conservationists, householders, and those working in professions likely to encounter bats during their work such as foresters, has not been adequately thought through in order to find sensible solutions. We are working closely with the SNCOs and Defra but are aware that their energies are being diverted away from conservation into a bureaucratic process, which will do little to enhance delivery of species conservation or meet the aims of the Habitats Directive. Adequate resourcing is required, not only in terms of Defra staff who are increasingly stretched on this issue, but also to enable guidance to be developed in consultation with experts and the target audience to ensure it is fit for purpose. We have written to Hilary Thompson of Defra stating our concerns on this matter and intend to do so again. We advocate a proportionate and strategic approach to implementing the protected species legislation to conserve bats long term, but the budget cuts and continual message of uncertainty is creating problems that could, if not managed correctly, lead to a public backlash against bats and great expense in legal proceedings and bureaucracy.

    5.6  Standardisation of guidance—An example of an area where guidance on standard procedures is urgently needed is for bat care, particularly in light of the proposed amendments to the Habitats Regulations which will require bat carers to be licensed from early next year. We have repeatedly proposed to Natural England that we can deliver such guidance given capacity to do so, however uncertainty over budget allocations has meant they are unable to commit any funds.

    5.7  Monitoring the effectiveness of mitigation for bats—The cuts in Defra's budget mean that there is no regular, systematic monitoring of mitigation that is implemented as part of derogation licences. Hence the effectiveness of such measures in maintaining Favourable Conservation Status of bats (one of the three conditions that have to be met for a Habitats Regulations licence to be granted) is not known. Consequently we question whether Defra can demonstrate that such licences are being granted legally. This monitoring is a statutory requirement under the Habitats Directive. A system is urgently needed to collate data on mitigation effectiveness and monitor cases to inform future developments and ensure licences are being granted within the law.

CLOSING REMARKS

  6.  BCT understands that Defra funding cannot be limitless. However, given continuing cuts and an environment of short term prioritisation and uncertainty, BCT is not able to collaborate effectively with related agencies to produce cost effective strategic solutions for the long term.

  7.  A joined up approach between Defra's agencies and also other government departments that impact biodiversity, for example DCLG, would give great potential to deliver not only bat conservation, but conservation of all Britain's biodiversity, our natural heritage.

Bat Conservation Trust

November 2006






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