Memorandum submitted by the Woodland Trust
1. The Woodland Trust welcomes the opportunity
to respond to this consultation. The Trust is the UK's leading
woodland conservation charity. We have four main aims: no further
loss of ancient woodland, restoring and improving woodland biodiversity,
increasing new native woodland and increasing people's understanding
and enjoyment of woodland. We own over 1,000 sites across the
UK, covering around 20,000 hectares (50,000 acres) and we have
300,000 members and supporters.
SUMMARY
— The Government is unlikely to meet
the 2010 biodiversity commitment as more species are now under
threat than at the inauguration of the UK Biodiversity Action
Plan (BAP).
— Biodiversity monitoring is only as
effective as the information gathered, yet given the complexity
of the ecological systems being analysed it is impossible to monitor
all species. This makes it important to have surrogate measures
for environmental health, of which the areas of both ancient semi-natural
woodland including wood pasture and parkland and semi-natural
open ground habitat are the most appropriate.
— Despite a recognition that conserving
biodiversity is a Government priority the legislative and policy
frameworks are still failing to protect important habitats including
ancient woodland, wood pasture and parkland and ancient trees.
— Defra's embracing of an ecosystem
approach is welcomed and it is imperative that the action plan
is delivered upon by all Government departments whose actions
can impact on biodiversity.
— There are multiple drivers for biodiversity
loss in the UK, many of which are occurring outside designated
sites, and thus conservation strategies must be applied more widely
and beyond site boundaries.
— Climate change impacts on UK biodiversity
are unpredictable and even modeling, such as MONARCH cannot help
improve certainty. Landscape scale principles build upon protecting
our existing wildlife resource and far greater investment should
be channeled towards reconnecting landscapes that offer the greatest
opportunities for putting wildlife on a sustainable ecological
footing. Climate change brings an increased urgency to adopt the
ecosystem approach.
— Planning policy is failing to protect
the environment. There is a sense that economic development always
takes precedence over environmental protection and that the UK
Sustainable Development Strategy is not being applied.
— Unfortunately at a time when climate
change makes it essential that adequate investment is allocated
to sustaining the environment, the Defra settlement within the
CSR actually represented a cut in real terms. This is already
having a detrimental impact on Defra and its subsidiary agencies.
— The UK protected area networks are
only a starting point for protecting biodiversity (a means to
an end not an end in itself) and much greater effort is needed
at a landscape-scale level, beyond designated site boundaries.
POLICY AND
PROGRESS
1. Is the Government on course to meet its
2010 biodiversity target?
2. Most headline indicators demonstrate
that the Government is not on target to meet its 2010 commitment.
However there is simply not enough evidence on declining species
from which Government can draw a reliable picture. Much research
is dedicated to "charismatic" species such as birds,
yet there is little examination into invertebrates, lichens and
fungi. The most serious consequence of this is that declines in
other sub-groups may go unnoticed or be far worse than those in
Government circles expect.
3. The previous PSA target was to move 90%
of Sites of Special Scientific Interest (SSSIs) into favourable
condition, and this has in most instances been achieved. However
we do not believe it is the most suitable measurement of biodiversity
because SSSI condition assessment takes no account of change in
adjacent land-use or climate change. Also the PSA gave no indication
of loss of non-designated wildlife sites such as ancient woodland,
wood pasture and parkland.
4. Decline of biodiversity is often complex
and linked to activity that is occurring outside of SSSIs and
other areas of conservation importance. Landscape scale principles
seek to build upon the tradition of site and species-based conservation
by increasing focus on how habitats complement one another, creation
of new habitats, re-connecting landscapes, making land-use more
sympathetic to help species move more easily, and taking action
across whole countries and regions. Importantly the Woodland Trust's
landscape-scale principles[34]
seek to demonstrate how society can benefits from a healthy natural
environment. This is very much in line with Defra's ecosystem
approach and services agenda, which we fully support. However
this agenda has been introduced too late for 2010.
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 assess
progress?
5. Bio-monitoring can only be as robust
and accurate as the information that is gathered and fed into
the reporting cycle. It is impossible to measure all species in
decline and as stated above there are likely to be species in
decline such as fungi and lower plants that we do not know about.
The Government should make use of broader habitat-based surrogates
such as the area of semi-natural woodland (ASNW) including wood
pasture and parkland, semi-natural open ground habitat (SNOGH)
and cumulative core area (CCA), as well as the species-based surrogates
for birds, bats, butterflies and plants already used in the 2010
indicators. The area of woodland by BAP priority habitat type
(2010 indicator 4) is not-well understood and as such a surrogate
of broadleaf woodland (from the National Inventory of Woodland
and Trees) is more commonly used. Ancient woodland, our most biodiverse
and irreplaceable woodland, can also be quickly assessed from
the Ancient Woodland Inventories providing ongoing losses are
recorded and the inventory maintained, as is the intention of
PPS9, Biodiversity and Geological Conservation, but which is not
yet happening. If these habitat-based surrogates were deployed
it would give a better reflection on the increasing scale of fragmentation
and habitat loss, which is something that must be reversed if
we are to have any chance of halting biodiversity loss and if
Government policy is to return biodiversity onto a sustainable
footing.
6. It is widely recognised that we do not
have an inventory of wood pasture and parkland outside of Northern
Ireland, and neither is there any assessment of the sustainability
of the ancient and veteran trees contained in such sites. There
is therefore no baseline against which to judge biodiversity loss.
7. Activity and reporting through the Biodiversity
Action Reporting System (BARS) is still problematic. There is
double counting in the system, and a lack of iteration between
the LBAP and UKBAP. Government must be careful that the limited
funding available is not simply channelled into managing BAP data
and indicators, rather than using monies to deliver action on
the ground.
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?
8. The policy and legislative frameworks
are insufficiently robust to offer genuine protection to biodiversity,
something that is best indicated by the amount of woodland under
threat from development. Woodland is one of the most widespread
semi-natural habitats in the UK and due to its complex structure
it provides home to wide range of wildlife. Indeed ancient woodland
contains more rare and threatened species than any other terrestrial
habitat in the UK and is recognised in PPS 9 for its importance
in supporting many priority species. However the Trust is aware
of 598 cases[35]
where ancient woodland, a scarce and irreplaceable source, is
coming under threat from development. From this it can reasonably
be concluded that polices that protect biodiversity are not being
enforced. There are numerous other cases that demonstrate the
policy and institutional frameworks are far too weak to prevent
loss of habitats and species in the face of development.
9. The UK BAP remains an important starting
point from which wider landscape-scale issues should now be addressed.
The embedding of an ecosystems approach at Defra demonstrates
real progress, but all departments and their agencies should recognise
that they too are responsible for ensuring successful implementation.
10. It is incumbent on all devolved administrations
to deliver on the BAP commitments and the wider ecosystem approach.
Life itself depends on the natural environment (for drinking water,
food, and clean air) and its protection should be at the heart
of all Government agendas. Disconcertingly the targeting of the
Northern Irish PSA has now altered the criteria for success to
the following: "To reduce significantly the loss of biodiversity
by 2010, and the halt of biodiversity by 2016"[36].
This is clearly a change from the EU Ministerial Agreement to
halt the loss of biodiversity by 2010. The aim may have been watered
down out of pragmatism, yet it could be very damaging if for political
expedience existing commitments were continually jettisoned. The
implementation of the sub-national review in England, which will
transfer planning powers to the economically driven Regional Development
Agencies, is another example where environmental concerns are
being sidelined in pursuit of development.
4. How well is biodiversity protection incorporated
into the policy-making process? How well does the Ecosystem Approach
Action Plan address this issue? Has there been enough progress
in ensuring that the value of eco-system services are reflected
in decision-making?
11. The embracing of the eco-systems approach
by Government is a definitive step forward and marked genuine
progress. Unfortunately it is most unlikely that the Ecosystem
Approach Action Plan will be implemented in time to achieve the
2010 target. However this should not detract from the importance
of an Ecosystems Approach, something which makes it all the more
vital to ensure that the policy prescriptions are shared by all
Government departments.
12. The eco-systems agenda can demonstrate
that biodiversity has an intrinsic value and is integral to delivering
the "services" upon which society is dependent such
as air purification, enhanced soil quality and flood alleviation,
clean water, pollinated crops and timber.
13. As the amount of ancient woodland and
other habitat threatened by development demonstrates, there is
clearly inadequate emphasis given throughout the decision-making
process to ecosystem services and to biodiversity protection.
To achieve the vision in PSA 28, Secure a healthy natural environment
for today and the future, a host of departments that previously
did not have environmental protection as a core indicator, should
now have their success or otherwise inextricably linked to the
delivery of the ecosystem approach.
KEY THREATS
5. What are the key drivers of biodiversity
loss in the UK, and is the Government addressing them
14. There are multiple drivers of biodiversity
loss in the UK, most probably compounding the impact of each other.
The most pressing and long term threats are often happening beyond
site boundaries, such as climate change, the results of infrastructure
development destroying or further fragmenting sites, both air
and water borne pollution, and the negative edge affects from
intensively managed land. The UK is still suffering from a legacy
of habitat removal and fragmentation making it more challenging
to restore biodiversity without ambitious actions at a landscape-scale
beyond designated site boundaries.
15. The ecosystems approach could link together
the diverse policy areas, not always under Defra's remit, that
drive biodiversity decline, and more importantly afford Government
an opportunity to arrest it. However if the UK is to reach its
commitment, far more determined action is required to both protect
semi-natural habitats and where possible, buffer and extend them
and ensure the wider countryside enables species to disperse,
survive and adapt the rigours of climate change.
16. An ecosystem approach is necessary because
the causes of biodiversity loss are so many and often happen outside
site boundaries. Climate change also brings with it an increased
urgency to embrace an holistic ecosystem approach to conservation
strategies. These drivers demonstrate that Government should protect
all important sites, increase the rate of habitat creation and
restoration, make wider land-use more sympathetic so that wildlife
is better able to disperse, guarantee that these actions are implemented
nationally, regionally and locally and ensure that the ecosystem
services we derive from the natural world are understood and reflected
in the priorities of all Government Departments.
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?
17. As it stands, the Invasive Non-native
Species Framework will not prove effective. It is near impossible
to prevent all invasions and there is no guaranteed methodology
to predict those species that will become invasive. Climatic uncertainty
makes gauging invasions even more challenging. If the Government
are to be successful they need to identify a lead agency and specific
funding for tackling invasions. Their strategy for identifying
areas most at risk, rapidly assessing whether there is a need
for action, and then if appropriate, targeting early action to
eradicate the invasion will not be successful without this leadership
and funding. Government cannot achieve this alone and any plausible
strategy will need the engagement of all stakeholders including
those in the business sector.
7. What impact will climate change have on
UK biodiversity? How might the impact of climate change be reduced?
How can potential change mitigation and adaptation measures and
biodiversity protection be effectively managed?
18. The impacts of climate change are uncertain
and it is vital that policy is not directed towards a preferred
future in the hope that this construct becomes reality. The Modelling
Natural Resources Responses to Climate Change (MONARCH) study,
to which the Woodland Trust was a contributor, demonstrated that
those species with northerly distributions will lose suitable
climate space in the UK leading to fragmented habitats and decreased
populations. This could be balanced by southern based species
if they are able to migrate northward, and therefore policy must
now be directed at a landscape-scale level, to allow species to
move to more suitable habitats.
19. In March 2008 the Trust hosted a conference
on adaptation to highlight some of the tensions between mitigation
and adaptation strategies, in particular how the burgeoning biofuel
industry may impact negatively upon wildlife. The Trust has also
contributed towards Defra's guidance on conserving biodiversity
in a changing climate. This argued for direct management to reduce
impacts, promotion of the dispersal of species, increase available
habitat, promotion of the conditions for natural ecosystems functioning,
optimise sectoral responses to climate change, and continue to
reduce pressures not linked to climate change.[37]
20. Climate change makes full adoption of
an ecosystems approach an urgent requirement.
8. Does planning policy adequately protect
biodiversity? Are effective measures in place to ensure that Government
plans for huge 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?
21. Both PPS 9 and the supplementary guidance
to PPS 1, Delivering Sustainable Development, recognise the value
of biodiversity and the habitats upon which it is dependent for
survival. Ancient woodland is an especially important habitat
for wildlife given its longevity and this was recognised in PPS
9 which stated that "Ancient woodland is a valuable biodiversity
resource both for its diversity of species and for its longevity
as woodland".[38]
However, as the Woodland Trust's own casework demonstrates, these
guarantees are not restricting development on environmentally
important areas. PPS9 also recognised the importance of aged and
veteran trees many of which are being lost before Local Planning
Authorities become aware of the threats to them. Without a TPO
to protect them they can be legally cut down before a planning
application is submitted.
22. The Trust contests many cases where
ancient woodland is under threat from development. One example
was Bramley Frith where a National Grid power station cited in
ancient woodland was expanded despite the irrevocable damage this
will now cause to the wildlife inhabiting the site. In the final
ruling of the Judicial Review little credence was given to PPS
9 and the importance this placed on protecting ancient woodland.
If Government is to deliver the type of landscape-scale action
implicit in the ecosystem approach and needed to return biodiversity
onto a sustainable footing and allow society to derive the services
upon which it is dependent, the protection for biodiversity already
afforded in the rhetoric of the planning system must be applied
more rigorously.
23. Biodiversity loss necessitates protecting
and restoring habitats, and where possible expanding them to benefit
both wildlife and people. It is therefore unfortunate that the
Planning Bill passing through Parliament will relax controls on
development thus risking further damage and loss. The recommendations
of the sub-national review, which might be legislated for in the
next Parliamentary session, will place planning controls in the
hands of the Regional Development Agencies who have traditionally
given little regard to environmental protection. This adds to
the sense that economic development takes precedence over the
social and environmental concerns.
24. Development on brownfield sites can
negatively impact on biodiversity because these areas of scrub
land have often developed into sanctuaries for wildlife. West
Thurrock Marshes is an example where development was granted on
brownfield land. In the final ruling little emphasis was given
to the environmental impact of development, and the decision could
now undermine the protections afforded to biodiversity in both
PPS 9 and section 40 of the NERC Act. Previously agreed controls
should be exercised to oppose development where it may impact
negatively on the biodiversity, irrespective of whether the land
is classified as "greenfield", "greenbelt",
or "brownfield".
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?
25. Unfortunately there are not adequate
resources being channelled into delivering the BAP, with a recent
report indicating that there was a short fall of £300 million
per annum, and that was for previous rather than new BAP priorities.
If the Government is serious in its intentions to halt the loss
of biodiversity there is a need for an eco-systems approach and
cross-sectoral support.
26. The Trust is also concerned by the cut
in the Defra settlement and the likely consequences this will
have on the BAP. At a time when climate change exerts greater
pressure on the Defra budget it is unnerving that little is actually
committed to biodiversity protection, restoration, and enhancement.
PROTECTED AREAS
10. Is the UK protected area network up to
the job of maintaining biodiversity, now and in 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?
27. Sites of Special Scientific Interest
(SSSIs) are vital building blocks in protecting biodiversity;
however they were only designed to be representative samples and
therefore do not pick up all valuable semi-natural habitats. Unfortunately
the previous PSA target of "favourable condition" is
wildly subjective and open to manipulation. Often condition assessments
are grossly fallible and sites are not in favourable condition
when analysed in the context of climate change and the impact
of adjacent land-use.
28. It should not be assumed that biodiversity
will be placed on a sustainable footing by directing vast sums
of public money into SSSIs. This may be the starting point, but
by isolating wildlife within SSSIs, the opportunity for landscape
scale action is lost, and neither will it enable species to migrate
in the face of irrevocable climatic change. Habitats have never
been static, and yet the Government's approach to SSSIs assume
not only a stasis but also that the surrounding countryside is
being managed sustainably. As demonstrated, land-use outside of
designated zones has a great effect on wildlife and if this is
not addressed may undermine opportunities for arresting biodiversity
decline.
29. The approach to managing non-native
species within SSSIs is unsustainable and demonstrates little
pragmatism or understanding of the inter-relationship between
species and habitat.
30. Article 10 of the EU Habitats Directive[39]
asks that Member States endeavour to improve ecological coherence
by managing sustainably those landscape features outside Natura
2000 sites which are important for species migration and dispersal.
Managing SSSIs alone will not be sufficient to achieve the spirit
of the Directive and there should be greater ambition in Government
thinking. Disappointingly Article 10 has never been transposed
into the UK's Conservation (Natural Habitats, &c.) Regulations
1994. The Trust's landscape-scale principles argue for action
across countries and regions rather than focusing solely on isolated
nature reserves. Action on this scale is necessary to enhance
SSSIs and afford greater opportunity to reconnect fragmented landscapes
and enhance biodiversity.
Annex One
THE WOODLAND TRUST'S LANDSCAPE-SCALE PRINCIPLES
The UK's fragmented landscapes and likely rates
of climate change threaten the survival of our natural world.
These principles aim to create sympathetically managed landscapes
that allow as many species as possible to adapt and move in response
to change.
We should:
— Focus conservation of individual
species on those believed to be fundamental to wildlife habitats.
Individual species can also be used to promote wider protection,
restoration or creation of wildlife habitats.
— Conserve all ancient woods and other
wildlife habitats not just selected sites.
— Consider how wildlife habitats complement
one another and accept that they have never been static. It makes
no sense to try to prevent change, especially in the face of climate
change.
— Restore all ancient woods and other
wildlife habitats planted with non-native conifers.
— Create new wildlife habitats where
nature is best-placed to survive, such as in areas where ancient
woods and other wildlife habitats are concentrated.
— Protect existing ancient woods and
other wildlife habitats from damaging uses of neighbouring land
by creating new wildlife habitats alongside them.
— Help species move across landscapes
more easily by using the wider countryside less intensively. This
means more than just creating new wildlife habitats that physically
link existing ones. Most rare or declining species are usually
unable to move far, but more sympathetic wider landscapes may
increase the one-off chances of individuals travelling a long
way.
— Think big! Take action across whole
countries or regions. Just creating large isolated nature reserves,
while we continue to use land unsympathetically around them, will
not help most species move in response to change.
— Make sure society also benefits from
action for nature. For example, improved air and water quality,
flood alleviation, high quality food and timber, better health,
soil conservation, employment opportunities and recreation. It
will only be possible to undertake the scale of action required
for nature if it also works for people.
June 2008
34 See Annex One, Woodland Trust Landscape Scale Principles. Back
35
Woodland Trust, Woods Under Treat Department, (May 2008). Back
36
Office for First Minister and deputy First Minister, Programme
for Government 2008-11, (2008), p. 52 at http://www.pfgbudgetni.gov.uk/finalpfg.pdf Back
37
Defra, Conserving biodiversity in a changing climate: guidance
on building capacity to adapt, (2007), at http://www.ukbap.org.uk/Library/BRIG/CBCCGuidance.pdf Back
38
Department for Communities and Local Government, PPS 9 Biodiversity
and Geological Conservation, (May 2006), p. 6, at http://www.communities.gov.uk/publications/planningandbuilding/pps9 Back
39
European Union, EU Habitats Directive (92/43/EEC), (May
1992), at (http://www.proact-campaigns.net/infoandlinks/id10.html Back
| 
