Memorandum submitted by the Horticultural
Trades Association
INTRODUCTION
The Horticultural Trades Association (HTA) is
the leading trade association for the ornamental horticulture
and gardening industry. HTA membership includes some 1800 businesses
representing the entire supply-chain—growers, retailers,
suppliers, and landscapers. HTA grower members represent approximately
80% of UK ornamental production and include all major UK growers.
HTA retail members include some 2500 retail nursery, garden centre
and DIY multiple retail sites. HTA also operates the Association
of Professional Landscapers, which represents landscapers, primarily
operating in the domestic arena. The HTA is run by and for the
industry and HTA performs a wide range of activities on behalf
of our members and the industry.
SUMMARY
As requested in the invitation to submit evidence,
this submission starts with a bullet-pointed summary of this response.
— The Government may be on course to
meet parts of its 2010 biodiversity target but not all of the
target.
— In our experience the HTA doubts
the effectiveness of the monitoring and reporting process, questions
how meaningful some of the indicators are, and believes that more
work is needed to acquire data upon which to define targets and
to assess progress.
— There is a need for more joined up
thinking and action to protect bio-diversity whilst achieving
a balance with the economic and societal needs of the UK.
— Whilst biodiversity protection is
incorporated in some aspects of the policy-making process more
could and should be done in this area.
— Key drivers of biodiversity loss
in the UK are many and varied, including economic drivers, social
drivers and conflicting needs of Government policy.
— The HTA has significant concerns
at the Invasive Non-Native Species Framework Strategy.
— Climate change is likely to bring
about new threats to UK biodiversity.
— Planning policy could do much more
to protect and encourage biodiversity.
— Whilst the UK protected area network
has played a significant role in maintaining biodiversity more
work could be done whilst recognising the need to balance different
demands on land use.
POLICY AND
PROGRESS
1. Is the Government on course to meet its
2010 biodiversity target?
1.1 Whilst the Government may be on course
to meet parts of its 2010 biodiversity target it is clear to the
HTA that not all parts of the target either can or necessarily
should be achieved by 2010. One example of this would be the target
for reducing peat use by 90%. The HTA is leading a cross-industry
group—the Growing Media Initiative—to address the
reduction of peat usage in horticulture. This group comprises
representatives of growing media manufacturers, retailers, NGOs,
growers and Defra. It is widely acknowledged that the industry
as a whole has taken great strides in increasing the amount of
peat-replacements used in horticulture. It is also widely acknowledged
that the absolute UKBAP target for 2010 cannot be achieved for
a number of reasons including the technical performance, price,
availability and environmental impact of alternatives. The HTA
is working closely with Defra and others to address these issues
and will continue to do so.
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 In our experience the HTA doubts the
effectiveness of the monitoring and reporting process, questions
how meaningful some of the indicators are, and believes that more
work is needed to acquire data upon which to define targets and
to assess progress. As outlined in paragraph 1.1 there are aspects
contained within the UKBAP where a greater balance is needed between
the needs of different players in any given sector, in order that
indicators and targets are credible and meaningful. The HTA believes
that the need for more and better data is recognised within Government.
This can be witnessed by the emphasis given in the ongoing Defra
consultation into a Soils Strategy for England. This consultation
clearly stresses the need for research into the properties of
soils and the risks to soils and therefore the biodiversity dependent
on those soils. The HTA contends that without this research to
fill knowledge gaps it is difficult, if not impossible, to define
targets and assess progress which is meaningful and credible to
all stakeholders.
2.2 The HTA is disappointed that the role
of gardens in protecting, maintaining and enhancing biodiversity
is almost totally ignored. The role of gardens should be given
a much higher profile in the UKBAP. Private gardens and plantings
around commercial sites have an enormous role to play. Research
for Lantra—the land-based sector skills council found that
there is an estimated 2.5 million private, domestic gardens in
the London region, covering 319 sq kilometres (123 sq miles).
These gardens contain two thirds of London's trees and collectively
support a rich and diverse fauna and flora that makes a major
contribution to London's sustainability and biodiversity.
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 The HTA believes that there is a need
for much more joined up thinking and action between different
policy and institutional frameworks to protect biodiversity and
recognise the other social, cultural and economic benefits of
plants and planting. The HTA, through our "Greening the UK"
campaign is working closely with a range of Government Departments
and agencies at both national and local level to address this
issue. These include DCLG, Defra, Natural England, the Town and
Country Planning Association and others. This campaign has already
seen around 60 local Councils agreeing to take action to increase
green plantings and enhance maintenance of existing areas, with
the protection of biodiversity being one of the drivers for action.
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 Whilst biodiversity protection is incorporated
into some aspects pf the policy-making process more could and
should be done in this area. One example of relatively good incorporation
into policy-making would be the Environmental Stewardship schemes
for agricultural producers. The HTA sees little evidence of such
incorporation in other areas such as construction apart from the
protection of a small number of high-profile species.
KEY THREATS
5. What are the key drivers of biodiversity
loss in the UK, and is the Government addressing them?
5.1 Key drivers of biodiversity loss in
the UK are many and varied, including economic drivers, social
drivers and conflicting needs of Government policy. Construction
in general—roads, houses, economic developments—is
a driver of biodiversity loss at local level but the HTA believes
that this needs to be balanced against the needs of people as
well. As mentioned in paragraph 3.1, the HTA is working to address
this balance by encouraging a greater emphasis on enhancing habitats
and therefore biodiversity in new developments. Whilst Government
recognises this in some areas, such as funding for parks in the
Thames Gateway project, Government could do much more to ensure
that other developments are required to take action on biodiversity,
rather than simply taking it into account.
6. Will the Invasive Non-native Species Framework
Strategy prove effective? Is there adequate regulation and resources
to prevent further invasions and to undertake eradication programmes?
6.1 The HTA has significant concerns at
the Invasive Non-Native Species Framework Strategy and the recently
concluded consultation exercise. The HTA has had good constructive
dialogue with regard to the non-native invasive species consultations
and taken an active part on various committees since the strategy
was started in 2001. The HTA along with the other participating
organizations was instrumental in producing the report which was
submitted to Defra in 2003. The HTA has provided support to these
consultations in kind and has featured prominently in all reviews
including a significant role in the production of the Horticultural
Code of Practice. It should be noted that the HTA has taken a
lead in ensuring that their members are fully updated on current
regulations with regards to non-native invasive plants.
6.2 The scientific justification underpinning
proposals within a Government consultation should be established
and available prior to that consultation being published. The
HTA considers that the strategy must not be based on anecdotal
evidence and a lack of objective science.
6.3 The addition of the listed plants in
the Review of Schedule 9 to the Wildlife and Countryside Act 1981
and The Ban on Sale of Certain Non-Native Species will have a
significant impact on our members and the trade in general. The
HTA is concerned that inclusion on Schedule 9 could lead to an
adverse reaction to those plants from an uninformed consumer press.
This could lead to economic damage to producers of those plants,
through a loss of sales for no valid reason.
7. 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 undoubtedly put
increasing pressure on UK biodiversity. With increasing globalisation
of trade we can expect to see greater risks of non-indigenous
pests and diseases threatening UK biodiversity. Particularly for
plant pest and diseases these risks are often not known at present.
The HTA urges government to ensure that adequate resources are
devoted to monitoring pests and diseases around the world and
assess their potential risk to the UK taking into account climate
change.
7.2 Understandably the major focus of action
on climate change relates to reducing emissions. The HTA believes
that there needs to be a much greater awareness of the positive
role that plants can play in mitigation and adaptation. That is
why we are investing members' money in sponsoring a three-year
PHD studentship at the University of Reading investigating and
analysing the role of gardening in climate change. The HTA believes
that Government could do more in working with industries such
as ours to fund such work.
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 HTA firmly believes that planning
policy could do much more not only to adequately protect biodiversity
but also to positively enhance it particularly as regards plants
and planting. The London Assembly has estimated that two-thirds
of front gardens in the London area—an area equivalent to
22 times the size of Hyde Park- are already at least partially
paved over, primarily to provide off-road parking spaces. This
has clearly had a huge negative effect on protecting biodiversity,
especially when taken in conjunction with the LANTRA research
quoted in paragraph 2.2. Planning policy to restrict car-parking
spaces in residential developments without taking into account
the desire of people to own cars and permitted development rights
to pave over front gardens is bound to lead to this conflict of
interest. The recent announcement by Government in Future Water—A
Water Strategy for England that permitted development rights to
pave over gardens with non-porous surfaces will be removed is
a welcome development. The HTA believes that greater action needs
to be taken in planning policy to ensure greater use of plants
and planting to deliver environmental and social benefits, including
for biodiversity. Whilst there are some good examples in new developments
around the country, in far too many developments there is little
or no green space. Even where soft landscaping plans have been
agreed with planning authorities as a condition for planning approval
anecdotal evidence suggests that too often these plans are not
seen through to fulfilment and that local planning authorities
have neither the skills nor resource to ensure enforcement.
8.2 The HTA urges Government to put further
measures in place to ensure that housing growth not only protects
biodiversity but also enhances it. The HTA urges Government to
insist that at least one of the final short-listed 10 candidate
Eco-towns must be an exemplar for public and private green space,
plants and planting and the enhancement of biodiversity. The Government
should also reconsider the make-up of its' Eco-towns advisory
group so that an acknowledged expert in landscape architecture
and the role of plants in the built environment is included.
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 The HTA believes that more can be done
to protect and enhance biodiversity as outlined in our answers
to the previous questions. However, we also believe that there
is a need for greater prioritisation within the existing resource
before Government provides more resources to biodiversity at the
expense of activities elsewhere. The HTA believes that closer
working between different parts of Government at an early stage
would lead to less duplication of work and less conflict between
different Departmental policies. This should lead to less waste
thus freeing up resource.
9.2 The HTA has no remit in the UK Overseas
Territories and is therefore not qualified to comment on this
issue.
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 Whilst the UK protected area network
has played a significant role in maintaining biodiversity more
work could be done whilst recognising the need to balance different
demands on land use. Different interest groups will always place
conflicting demands on any given situation. For example, growers
wishing to abstract water from rivers for irrigating crops for
economic reasons, whilst boat-yard owners wanting to keep as much
water as possible in rivers for their own economic reasons. The
HTA recognises that striking the right balance between maintaining
biodiversity and allowing economic activity is not easy. The HTA
is willing to help where we can in striking that balance.
May 2008
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