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 BCTaffecting 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 DevelopmentAnother 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 CaseworkBCT 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 HelplineThe 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 commitmentsGrants
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 BCTaffecting thousands of volunteers dedicated to
bat conservation. These aspects are outlined in turn below:
4.1 Designated sites monitoringWe
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 monitoringBCT
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 engagementOur
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 managementBCT 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
legislationWe 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 guidanceAn
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 batsThe 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
1 Not printed. Back
2
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