Memorandum submitted by the Grasslands
Trust
The Grasslands Trust is a registered Charity,
formed in 2002. It is the only charity in the UK whose sole purpose
is to conserve grasslands of importance for their wildlife, landscape,
cultural and community values. We purchase threatened grassland
sites and support other organisation to purchase them; campaign
to improve the policy environment for threatened grasslands; work
with local communities to cherish their local grasslands; provide
expert advice to grassland owners on management to benefit wildlife;
and raise the awareness of the public and decision-makers to the
plight of grasslands in the UK. We work in partnership with a
wide range of organisations, from within the Statutory, Voluntary
and Local Government Sectors, as well as individual landowners,
to deliver our aims.
The Grasslands Trust is an active member of
the Wildlife and Countryside Link Biodiversity Working Group and
a leading member of the UK Lowland Grasslands Habitat Action Plan
Steering Group. We offer this evidence to the Committee based
on our experience of working within the Biodiversity Action Plan
(BAP) process and with relevant associated policy areas, such
as the implementation of the Environmental Impact Assessment (Agriculture)
Regulations, planning policy (specifically Eco-Towns), DEFRA's
recent Environmental Stewardship Review of Progress, and a review,
with Flora Locale, of the state of grasslands in Wales.
The comments below are confined mostly to England
and Wales, as the Grasslands Trust does not yet operate in Scotland,
Northern Ireland or the Overseas Territories.
EXECUTIVE SUMMARY
— The Government is not on course to
meet the 2010 Biodiversity Target especially for priority grassland
habitats.
— There are significant gaps in the
information on extent and condition of priority grassland habitats
outside of the protected areas network.
— The Ecosytems Approach and the BAP
process are poorly connected.
— Key drivers of grassland biodiversity
loss are still intensive agriculture and development, but abandonment
is increasingly significant.
— The Environmental Impact Assessment
(Agriculture) Regulations are failing to protect small grasslands.
— The current planning policy framework
has the potential to deliver significant biodiversity benefits,
but that potential is not realised.
— SSSIs are necessary but not sufficient
to meet biodiversity targets.
— Resources need substantial increase,
particularly for Local Wildlife Sites and habitat creation.
POLICY AND
PROGRESS
1. Is the Government on course to meet its
2010 biodiversity target?
1.1 The Grasslands Trust doest not believe
that the Government is on course to meet its 2010 biodiversity
target. Wildlife and Countryside Link's progress assessment published
in March 2008 showed no change in the state of all but two indicators
originally assessed in January 2006, based on data from the 2005
Biodiversity reporting round. Of the two indicators that had changed,
one "no BAP priority habitats or species still declining
by 2010" had actually slipped from Amber to red/amber, while
the other "95% of UK SSSIs and ASSIs in favourable condition
by 2010" had improved from amber/green to green[1].
1.2 These figures are aggregated for all
BAP species and habitats though. For grassland habitats the situation
is considerably worse. In a written answer on 14 June 2007[2],
the then Biodiversity Minister Barry Gardiner MP informed the
House that the 17 priority habitats that were still declining
included all the lowland grassland habitats and associated habitats
where grassland is a significant component, namely lowland meadows,
lowland calcareous grassland, lowland acid grassland, purple moor-grass
and rush-pasture, lowland wood pasture and parkland, fens, and
coastal floodplain and grazing marsh. Upland hay meadows were
also listed as continuing to decline.
1.3 Although for most of these grassland
habitats the 2005 reporting round indicated that the decline was
now slowing, and it remains to be seen what the 2008 reporting
round will conclude, it seems very unlikely that the decline will
have stopped, let alone reversed, in the next two years.
2. How effective is the biodiversity monitoring
and reporting process? Are the biodiversity indicators meaningful?
Is there adequate data upon which to define targets and to assess
progress?
2.1 The BARS mechanism has the potential
to be an effective way to collect biodiversity information at
national and local level, but is dependant on the willingness,
enthusiasm and above all the resources available for each contributor
to provide useful input. This is particularly true of Local Biodiversity
Action Plan partnerships, where insufficient resources prevent
adequate reporting to BARS. This will then limit the accuracy
of the data within BARS.
2.2 Unlike for many other priority habitats,
for priority grassland habitats there are significant gaps in
the data on extent and condition of grasslands, both in England
and especially in Wales. This is in part due to grasslands traditionally
having been the "Cinderella" of nature conservation,
many grasslands having been ignored as uncharismatic or not supporting
species with a high public profile. Also, small grassland sites
can be difficult to access and identify, tucked away within farms
on private land in remote parts of the country.
2.3 Significant areas of Wales do not have
working wildlife site systems, so what little remains of the resources
of priority grassland habitats is unmapped, unidentified and unprotected[3].
3. Are the policy and institutional frameworks
effective at protecting biodiversity? Is biodiversity protection
addressed effectively at local and regional levels? How successful
has the UK Biodiversity Action Plan been? Does Conserving biodiversity—the
UK approach address the need to have a joined-up approach to biodiversity
protection with the devolved administrations?
3.1 There is a significant risk that the
forthcoming devolution of the UK BAP structures, particularly
the shift from UK habitat groups into country-based groups, will
make a joined-up UK overview increasingly difficult to maintain.
4. How well is biodiversity protection incorporated
into the policy-making process? How well will the Ecosystem Approach
Action Plan address this issue? Has there been enough progress
in ensuring that the value of ecosystem services are reflected
in decision-making?
4.1 At present the Ecosystem Approach and
the Biodiversity Action Plan approach appear to be on parallel
tracks. Does the Government intend to replace one with the other?
Only landscape-scale action will ultimately achieve the aims of
conserving biodiversity, particularly in the light of climate
change and other ever-increasing pressures on the environment.
While the economic value of services provided by biodiversity
(as integral components of ecosystems) to society and the economy
should be elaborated and where possible enumerated, it should
not be forgotten that the intrinsic value of biodiversity is a
concept enshrined within the Convention on Biological Diversity.
There is a danger that a slavish adoption of the ecosystems services
approach will devalue those species and habitats where an economic
value cannot be placed on their conservation.
KEY THREATS
5. What are the key drivers of biodiversity
loss in the UK, and is the Government addressing them?
5.1 The Grasslands Trust believes the key
drivers behind lowland grassland losses are:
— Neglect or abandonment.
— Agricultural intensification.
— Inappropriate management in particular
overgrazing by horses.
— Development pressures from housing
and infrastructure development, and associated recreational activities.
— Diffuse pollution threatens grasslands
associated with low fertility soils.
5.2 While relatively few grasslands sites,
compared to previous decades, are being wilfully destroyed by
agricultural practices, there are still insidious losses associated
with inappropriate management and abandonment. Small unimproved
grasslands often do not fit into modern agricultural operations
and are abandoned. Small fields also command high prices as horse
and pony paddocks, and become heavily overgrazed, and this can
be very detrimental to the wildlife that previously occurred there.
Grasslands within urban areas or on the urban fringe are subject
to recreational damage, such as from dog-walking, which disturbs
wildlife such as ground-nesting birds, and also provides unwanted
nutrients. Diffuse pollution from agriculture, and also nitrates
associated with vehicle emissions, effectively adds low doses
of fertiliser to grasslands, subtly changing their ecology to
the detriment of grassland wildlife.
5.3 One mechanism the Government claims
is effective in preventing losses of grassland habitats as a result
of agricultural intensification is the Environmental Impact Assessment
(Agriculture) Regulations 2006. This regulation implements the
EC Environmental Impacts Assessment (EIA) Directive as it affects
agriculture. Initially introduced in 2001, The Regulations were
revised in 2006 partly as a result of the Better Regulation Agenda
arising from the Hampton Review. The outcome of the revision has
left the regulation effectively toothless to act against agricultural
activities threatening priority grassland habitats.
5.4 One of the most serious loopholes introduced
in the 2006 Regulations was a minimum size threshold of 2ha, below
which the Regulations do not apply. This effectively gives impunity
to landowners to destroy grasslands where there is less than 2ha
of BAP quality habitat. Defra argued that fragments below 2ha
were not significant, but evidence presented by English Nature
at the time the Regulations were being reviewed showed that a
significant number of priority grassland fragments that suffered
damage from agriculture were below 2ha in size.
5.5 Another loophole within the Regulations
relates to the quality threshold for protection: the BAP habitat
definitions are restricted to unimproved grasslands, and the EIA
Regulations apply these definitions strictly. So slightly semi-improved
grasslands, which are still very important wildlife habitats,
and in some counties are the only grasslands supporting wildlife
outside of the protected areas network, are not subject to protection
against agricultural intensification.
5.6 Finally the EIA Regulations do not apply
to damage caused by horses or ponies, unless those animals are
only using the grasslands for grazing. Most equestrian use includes
feeding with hay, and therefore exempts such damage from the EIA
regulations.
6. What impact will climate change have on
UK biodiversity? How might the impacts of climate change be reduced?
How can potential conflict between climate change mitigation and
adaptation measures and biodiversity protection be effectively
managed?
7.1 Climate change will have a significant
impact on grassland habitats, partly because most grasslands,
particularly in the lowlands, are so highly fragmented. Wildlife
populations that will need to move in response to climate change
will find it more difficult in fragmented landscapes than those
with a high level of connectivity between habitats. Theoretically
this problem can be alleviated with a landscape-scale approach,
by providing linkages between existing grassland fragments, for
example through habitat creation. In practice though, the funds
which should be available to create the linkages ie Agri-environment
schemes such as Environmental Stewardship or Tir Gofal, are inadequate
to supply all the multiple objectives now expected of them. Indeed
in England, Natural England proposes to focus 80% of its spending
on Higher Level Schemes onto only 20% of the land—this will
inevitably reduce the ability of this flagship scheme to deliver
connectivity through habitat creation on the excluded 80%. Conversely,
the widely available Entry Level Scheme, open to all landowners,
does not provide funding for habitat creation and therefore cannot
provide the connectivity needed. It is therefore unclear how Environmental
Stewardship will deliver on its stated aims to enable wildlife
to adapt to inevitable climate change, given its inability to
support one of the key mechanisms for adaptation.
8. Does planning policy adequately protect
biodiversity? Are effective measures in place to ensure that Government
plans for housing growth (including eco-towns) enhance rather
than damage biodiversity? Should there be a review of greenbelt
policy, and what might the consequences be for biodiversity? Do
guidelines encouraging development on brownfield sites risk damaging
biodiversity?
8.1 The Spatial Planning Policy Framework
of Regional Spatial Strategies and Local Development Frameworks,
coupled with effective use of Planning Policy Statement 9 and
the Section 41 Biodiversity Duty on public bodies, does have the
capacity to provide a greater level of protection for biodiversity
than previous planning policy frameworks. However, this increase
in protection will only happen if planning departments within
local planning authorities are given the necessary training and
encouragement to deliver such protection. And this will only happen
with a substantial increase in the quality of guidance and encouragement
provided to them from the Department for Communities and Local
Government.
8.2 The Grasslands Trust believes there
is a great opportunity to incorporate high quality grasslands
within the green infrastructure of new developments and to increase
the quality of existing green infrastructure within existing urban
areas. The Eco-towns concept is a good example—we are working
closely with the Town and Country Planning Association, RSPB,
Natural England and others to develop guidance on green infrastructure
for Eco-towns because there is considerable scope to create new
grassland habitats within Eco-towns. It is unacceptable that any
of the bidding Eco-towns should cause damage or destroy existing
important grassland habitats during their development.
RESOURCES
9. Are there adequate resources for biodiversity
protection and enhancement? Has the Government addressed the need
to provide additional support for biodiversity protection in the
UK Overseas Territories?
9.1 Significant resources have been pumped
into the SSSI network in England in recent years in order to meet
the 2010 PSA target for to deliver favourable condition on SSSIs.
Arguably this has been done at the expense of some biodiversity
outside of protected areas, as sites that had previously been
receiving agri-environment funding through Countryside Stewardship
and Environmentally Sensitive Areas schemes (now called the Classic
Schemes), failed to gain entry into the Higher Level Scheme, whose
funds have been focussed on SSSIs. While Entry Level Scheme is
available to all land-owners, the payments are less than half
what would have been paid through the Classic Schemes, and it
is unclear to what extent ELS provides biodiversity protection,
but certainly little if any biodiversity enhancements, as previously
discussed.
9.2 Local Grassland Projects such as Pastures
New[4]
in Dorset have tapped into alternative resources recognising that
the main supply of financial resources (ie Agri-Environment Schemes)
is not sufficient in itself to deliver biodiversity for key areas.
Pastures New uses resources from Local Area Agreements and support
from Charitable Trusts to deliver a landscape-scale project, providing
advice to grassland owners, paying for capital works such as fencing
where Agri-environment resources are unavailable, and setting
up a local project to help graze abandoned sites. Thus a relatively
small additional resource can substantially enhance the quality
of the products provided by Agri-environment scheme funding. This
approach should be applied more widely across the UK.
9.3 Thus far Tir Gofal the Agri-Environment
Scheme in Wales has failed to deliver significant biodiversity
benefits and a timely review of this scheme is now underway. An
added value approach such as described above would also help deliver
biodiversity benefits from the forthcoming revised scheme.
9.4 One source of resources that has not
been effectively tapped for biodiversity protection and enhancement
is the land-value uplift associated with a change from agricultural
use to development land, as a result of housing or other development
activities. It is now possible, as a result of PPS 9, for local
planning authorities to require developers to incorporate green
infrastructure, including habitat creation and enhancement for
biodiversity, and that this be paid for from the "windfall"
profits associated with land value uplift. Sadly this is not happening
to any great extent at the moment, but with the forecast of three
million new homes to be built by 2020, this is an opportunity
to not only provide healthy living environments for those homes
to be built within, but also to deliver habitat creation, restoration
and maintenance targets for grassland and other priority habitats.
PROTECTED AREAS
10. Is the UK protected area network up to
the job of maintaining biodiversity, now and into the future?
Are arrangements to protect sites effective? Is more work needed
to reduce habitat fragmentation and to link up those semi-natural
habitat areas that remain?
10.1 SSSIs in England are at least improving
in condition, as a requirement of the 2010 PSA target. There is
no doubt that the actions to deliver the PSA target will have
improved the status of some of the species and habitats on these
SSSIs. Grassland within SSSIs is often not specifically mapped
or recorded so it is difficult to ascertain to what extent improving
SSSI condition per se has improved the state of grassland habitats
or the species that depends on them.
10.2 The situation in Wales is far more
serious—the most recent figures available from CCW show
that most grassland in SSSIs in Wales is in unfavourable condition—78%
of lowland acid grassland, 80% of lowland calcareous grasslands
and 81% of lowland meadows were unfavourable[5].
10.3 SSSIs will be an essential component
of the network of sites needed to protect wildlife both from the
existing pressures of agricultural intensification, abandonment,
development, recreational use and pollution, and from the longer
terms threats associated with climate change. However, on their
own they will not be sufficient.
10.4 A larger network of Local Wildlife
Sites also exists with a much smaller degree of protection; and
information on these sites is more scant than for SSSIs. Local
Wildlife Sites deserve far greater attention than they are currently
receiving, both in terms of assessing their condition, providing
resources for their management, and ensuring their protection.
Given that, at least in England, no more SSSIs are planned to
be designated, except to satisfy the requirements of European
Directives, it is even more important that Local Wildlife Sites
are given greater attention.
10.5 It will also be necessary to restore
sites currently not sufficiently valuable to be recognised as
County Wildlife site quality, in order to buffer existing high
quality sites from intensive agriculture for example, and to link
existing high quality sites together. Unfortunately there are
now fewer resources available to support habitat creation or restoration
through Agri-environment schemes than there were previously. This
situation needs to be reversed and truly landscape-scale projects
developed, with sufficient funding, to create wildlife-rich landscapes,
resilient to climate change.
11. In conclusion, The Grasslands Trust
believes that Biodiversity, and especially grasslands, in the
UK are still under threat. The Biodiversity process needs to be
strengthened and integrated with the Ecosystems approach. More
resources are needed and more imaginative ways of making the most
of the available resources.
30 May 2008
1 Halting Biodiversity Loss by 2010: A progress
assessment by Wildlife and Countryside Link. March 2008 Back
2
Hansard 14 Jun 2007 Columns 1199W & 1200W. Back
3
Manifesto for the Wild Meadows of Wales. Flora Locale and the
Grasslands Trust. 2008 Back
4
http://www.dorsetaonb.org.uk/text01.asp?PageId=308 Back
5
Sites of Special Scientific Interest in Wales. Current State
and Knowledge. Report for April 2005-April 2006. Countryside Council
for Wales Back
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