Memorandum submitted by the Wildlife Trusts
INTRODUCTION
1. The Wildlife Trusts (TWTs) welcome the
opportunity to respond to the Environmental Audit Committee Inquiry
into "Climate change and local, regional and devolved
government".
2. There are 47 local Wildlife Trusts across
the whole of the UK, the Isle of Man and Alderney. We are working
for an environment rich in wildlife for everyone. With more than
720,000 members, we are the largest UK voluntary organisation
dedicated to conserving the full range of the UK's habitats and
species whether they be in the countryside, in cities or at sea.
We manage 2,200 nature reserves covering more than 80,000 hectares;
we stand up for wildlife; we inspire people about the natural
world and we foster sustainable living. For more information on
The Wildlife Trusts, please refer to www.wildlifetrusts.org
3. The Wildlife Trusts are heavily engaged
in policy and delivery on climate change adaptation at national,
regional and local levels. We work closely with local authorities,
regional bodies and devolved administrations on a range of aspects
of climate change adaptation, from strategy and planning to land
management and community development. We have been instrumental
in highlighting the importance of climate change adaptation for
wildlife and people to decision makers, and in particular:
— Habitat opportunity mapping to inform
planning decisions, and involvement in development control.
— Local and regional climate change
action plans.
— Biodiversity adaptation including
Local Wildlife Site systems and Biodiversity Action Planning.
— National policy development including
membership of the Defra Ecosystems Approach steering group.
4. The Wildlife Trusts have produced a strategy
document entitled "A Living Landscape" which
calls for the restoration of the UK's fragmented ecosystems, for
wildlife and people. This report sets out The Wildlife Trusts'
position and vision of the future with regard to adaptation to
climate change but also provides numerous case studies of landscape-scale
conservation schemes. The case studies demonstrate where we are
directly engaged in delivering the adaptation changes required
on the ground, and the holistic benefits that this work can bring.
The document is available to download from the "publications"
page of www.wildlifetrusts.org
5. We would be pleased to provide further
information in relation to points raised in this response.
6. This response focuses on climate change
adaptation. Whilst The Wildlife Trusts recognise the importance
of climate change mitigation measures, we believe that other bodies
are better placed than us to comment on mitigation in relation
to local, regional and devolved government. The Wildlife Trusts'
considerable skills and expertise on climate change adaptation
means that this forms the principal focus for our submission.
GENERAL COMMENTS
7. The Wildlife Trusts believe that local,
regional and devolved government must give climate change adaptation
the same urgency and priority as they have given to climate change
mitigation. This is essential if each level of government
is to respond to the unavoidable impacts of a changing climate,
and an unpredictable future. Indeed, we believe that environmental
adaptation is essential to underpin our climate change response
for both wildlife and people, providing wide ranging solutions
for issues such as flood risk and water management, farming and
fuel production, recreation, industry and social development.
8. The scale at which climate change adaptation
operates is significant, and local, regional and devolved governments
will need to work at a landscape-scale in order to plan and deliver
effectively. Operating on a site by site basis will be insufficient,
and authorities will need to consider the functioning of whole
ecosystems rather than simply individual components within them,
to maintain and enhance the resilience and connectivity of the
natural environment.
9. Operating at an ecosystem and landscape-scale
will require a robust information base and habitat opportunity
mapping will be required across all local, regional and devolved
government areas to inform the planning and land use decision
making required for climate change adaptation.
10. At sea, the most effective climate change
adaptation measure should be the introduction of new marine legislation.
SPECIFIC COMMENTS
How can central government best support and encourage
local authorities, regional government and devolved administrations
to take action on mitigation and adaptation, and other climate
change related areas like waste and transport? What funding, powers
and structures are required to improve joined up delivery of climate
change policy at all levels of government?
11. The Stern Review has warned us of the
economic consequences of not prioritising environmental climate
change adaptation. We must therefore see real joined up central
Government in our response, with a focus on long term sustainable
development and quality of life, rather than simply short term
economic gain. Whilst we are seeing some positive steps from central
Government in this direction (eg with the recent launch of the
Defra Ecosystems Approach and Action Plan), policy join up across
departments is weak. Proposed reforms in planning and regional
governance for example within CLG, threaten to undermine the concept
of environmentally sustainable development by giving disproportionate
weight to economic growth. Central Government needs to show
greater leadership on climate change adaptation with joined up
policy across departments and a strong steer for local, regional
and devolved administrations.
12. There are two particular areas of policy
that would support climate change adaptation (others are highlighted
later in this submission in response to specific questions). The
first is to ensure that changes in regional governance in England
result in a new body with sustainable development at its heart
and with proper accountability and representation. This would
mean that planning decisions would take appropriate account of
the natural environment, and the proposed Integrated Regional
Strategies would have an effective environmental component in
the face of climate change (see attached briefing on changes in
regional governance in England). The second is to place a new
duty on all public bodies for sustainable flood management.
This would promote more appropriate land management and development
to take account of climate change adaptation, and would also provide
an effective means of transposing the new EU Floods Directive.
Is there clarity about the role played by local
authorities, regional governments and devolved administrations
in tackling climate change? How can their actions be coordinated
and monitored? How can accountability and transparency of the
response at a local level be improved? How effective has the Nottingham
Declaration process been?
13. Duties already exist on public bodies
to take account of climate change adaptation such as the biodiversity
duty in the NERC Act 2006. However, The Wildlife Trusts believe
that greater emphasis and encouragement is required for public
bodies to understand, prioritise and resource this duty as a response
to climate change. Local and regional bodies can meet many
of their climate change adaptation needs by focusing on biodiversity
measures such as operating Local Wildlife Site systems to Defra
common standards, managing their own land holdings to benefit
biodiversity, bringing protected sites into favourable management
condition, and planning large-scale habitat restoration and creation
programmes.
What, if anything, needs to be changed in the
framework governing the actions of devolved administrations, regional
government and local authorities? For example, does there need
to be a more explicit reference to climate change in the local
government performance framework and will the new performance
indicators on climate change be enough to stimulate action?
14. The current climate change adaptation
indicator within the local government performance framework is
a good starting point for action. However, this is a process target
for producing adaptation strategies and requires complementary
outcome targets on delivery of the adaptation response. The indicator
on local biodiversity provides one measure of such an outcome,
highlighting the performance of Local Wildlife Site systems. The
Wildlife Trusts recommend that these two indicators are promoted
and used together to encourage a strategic approach and effective
delivery of climate change adaptation. We also believe that the
climate change adaptation indicator should be seen as an underpinning
measure which influences activity in other areas such as planning,
transport, waste and water.
15. The challenge for local government is
that these two indicators are adopted within Local Area Agreements
and that funding is attached to them. The Wildlife Trusts believe
that greater encouragement should be provided to Local Authorities
and regional bodies on the critical importance of climate change
adaptation as well as mitigation, and that these indicators should
be adopted as priorities.
To what extent should there be disaggregated targets
for different levels of government? How should independent targets,
for example Scotland Hwill set its own emissions target for 2050
(80% reduction rather than UK target of 60%) and the Greater London
Authority has committed itself to making a 60% cut by 2030, fit
together with national carbon targets and budgets? How can Government
monitoring and forecasting of emissions be improved so as to disaggregate
emission, and the impact of carbon reduction policies, in different
regions and nations?
16. The Wildlife Trusts believe that there
is a role for targets in relation to adaptation as well as mitigation,
for example the local government indicators and targets mentioned
above for Local Wildlife Site systems and climate change strategies.
Targets also exist for condition of Sites of Special Scientific
Interest and for habitat maintenance, restoration and creation
within local, regional and country Biodiversity Action Plans (BAP).
The Wildlife Trusts believe that UK BAP habitat targets set
within regional and local habitat opportunity mapping should form
the basis for targets for adaptation of the natural environment
to climate change.
How advanced and coordinated are local, regional
and national programmes of adaptation to climate change? What
support is there for adaptation? How vulnerable to climate change
are local authorities, regional government and devolved administrations?
17. Regional and local climate change action
plans are being developed across the country, but have a varied
level of priority afforded to adaptation. The Wildlife Trusts
believe that greater coordination and guidance is required for
these plans to be effective, with outcomes focused on resilient,
functioning ecosystems and habitat connectivity. Green infrastructure
plans and studies are also being developed in response to growth
and housing development. It is essential that these plans take
proper account of the needs of wildlife in relation to climate
change adaptation and do not simply view green infrastructure
as recreational space.
18. Local authorities are impacted directly
by climate change through management of their own land, public
spaces such as parks and through programmes such as tree planting
and maintenance. Further work is needed to encourage demonstrations
and models of climate change management of such spaces to promote
adaptation for wildlife and encourage use by people. Greater coordination
and consideration should also be given to the role of land management
more broadly in supporting climate change. For example, in the
uplands mechanisms are required to promote restoration of peatlands
(having added benefits of carbon and water storage), or encourage
sustainable farming and forestry practice.
How should the Committee on Climate Change reflect
the interests and needs of the different levels of government
across the UK?
19. The Wildlife Trusts believe that
the Committee on Climate Change should have balanced expertise
and representation from those involved in climate change adaptation
in addition to mitigation. The Committee should also have
balanced representation across the interests of sustainable development,
reflecting the natural environment, social issues and economics.
What are the barriers to greater local or regional
action? Do different levels of government have sufficient powers
to take action? What changes in policy are needed to support action
at a local level? What policies are working well?
20. There are several barriers that exist
to local or regional action on climate change adaptation. Many
of these stem from the lack of joined up policy making from central
Government which is reflected in decisions at local and regional
level, and from the need for better strategic planning for adaptation
through habitat opportunity mapping.
21. For example, the proposed changes
in the current Planning Bill threaten action at the local level
by determining Nationally Significant Infrastructure Projects
without local consultation. This will result in physical barriers
that damage existing habitat, prevent habitat expansion and block
species movement.
22. Conflicts in priorities also threaten
effective adaptation, such as pressure for hard flood defences
in all flood risk areas rather than integrating these with natural
solutions, or pressure for development on sites that are strategically
important for adaptation. The Wildlife Trusts believe that
greater emphasis needs to be placed on habitat opportunity mapping
to help direct decision making of local, regional and devolved
government.
What impact will the new Planning Policy Statement
on climate change have on emissions reductions and work on adaptation?
How are the so called "Merton rules" affected? How might
other planning guidance be changed to reduce emissions?
23. The new Planning Policy Statement on
climate change is weak on adaptation and in itself is unlikely
to promote the urgency and scale of the task of our response to
climate change impacts. The Wildlife Trusts welcome the recent
climate change amendment announced to the Planning Bill, that
highlights:
"Development plan documents must (taken
as a whole) include policies designed to secure that the development
and use of land in the local planning authority's area contributes
to the mitigation of, and adaptation to, climate change".
24. This goes some way to ensuring that
planning takes account of the needs of climate change adaptation,
but further clarity is required. For example, more emphasis
is required to stress the importance of protecting the integrity
of the SSSI system in the face of major infrastructure projects.
Are local authorities meeting their duty to
enforce building regulations in relation to environmental measures?
Does the enforcement regime discourage non-compliance?
25. Building regulations should be considered
to promote climate change adaptation as well as standards to reduce
emissions. The Wildlife Trusts believe that stronger regulations
to promote adaptation are required that include siting, provision
of services such as sustainable urban drainage schemes, use of
landscaping (including green roofs and green walls) and greenspace
management.
What good practice is there to be shared?
How is best practice shared and does central government support
sharing best practice work? What role should UK Climate Impacts
Programme, IDeA, Salix Finance, the Carbon Trust and Energy Savings
Trust play in providing support?
26. Good practice should also be seen in
relation to adaptation as well as mitigation. The Wildlife
Trusts have significant expertise in this area with approximately
150 landscape-scale initiatives under development to promote climate
change adaptation. Greater integration is needed between statutory,
public and voluntary sector bodies at local and regional level
to share expertise and coordinate activity on climate change adaptation.
3 January 2008
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