Memorandum submitted by the Association
of Local Government Ecologists
SUMMARY
Despite the many positive measures to conserve
biodiversity including a number of notable successes in recent
years, ALGE feels that the UK Government is not on course to meet
the 2010 target of halting biodiversity loss. The main reasons
include:
— Biodiversity legislation and policy
focuses predominantly on the protection of sites and species.
A dual approach that seeks to protects important habitats but
also creates greater opportunities to create new biodiverse landscapes
outside protected areas is required.
— The failure to systematically value
ecosystem services that biodiverse landscapes provide society.
— The lack of a national spatial strategy
for adaptation of biodiversity to climate change.
— The lack of comprehensive, systematic
and up-to-date comparative field data on habitats and species,
particularly at the local and regional scale.
— A lack of statutory biodiversity
performance standards for public bodies including local authorities.
— Recent cutbacks to agencies championing
nature conservation.
— The relatively limited ability of
environmental stewardship schemes to deliver the scale of biodiversity
improvements required.
POLICY AND
PROGRESS
1. Is the Government on course to meet its
2010 biodiversity target?
1.1 Whilst ALGE supports the many positive
attempts to conserve biodiversity through legislation, policy
and the development of the UK Biodiversity Action Plan system
it appears unlikely the Government will meet the 2010 biodiversity
targets without a policy shift and increase in resources that
gives greater weight to creating opportunities to enhancing biodiversity
comparable to the effort placed on protecting the UK's existing
important resources. Evidence from our members suggests that whilst
opportunities exist to create more biodiverse landscapes outside
the protect areas network, these are not being realised, partly
due to the already limited resources being allocated to maintain
and enhance statutorily protected sites.
1.2 Halting biodiversity loss will require
significant changes to the management of the landscape outside
designated areas. Whilst the ELS and HLS provide one means of
helping achieve the scale of change required, an increase in resources
appear to be needed if a halt in biodiversity is to be achieved.
Giving greater recognition and valuing the natural eco-system
services landscapes can provide to society through better protection
and manage could potentially provide significant benefits. Greater
integration and more cost-effective means of achieving sustainable
land management in both the rural and urban environments could
provide significant benefits and opportunities for biodiversity
enhancement.
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 Evidence from our members suggest a
lack of inadequate systematic, comprehensive and comparative field
data is being collected on habitat losses (and gains) on which
to make an accurate judgement of the state of biodiversity in
the UK, or to set targets at the local and regional level. Data
collected on a national basis, has limited value locally whilst
locally collected data collected on a comparative basis data has
the potential to meet local, regional and national needs. Traditional
habitat survey methods, often providing the baseline on which
comparisons of change are evaluated, tend not to easily translate
into current biodiversity priority habitat definitions. Currently
there is no statutory requirement for any agency to collect biodiversity
data. although significant amount are collected at a County or
district level by Local Authorities, Wildlife Trusts and Local
Record Records Centres). Many gaps in coverage exist and no formal
systems for collating information nationwide. Although Natural
England has been collating information on UK Biodiversity Priority
Habitats in England, which is being used to set regional biodiversity
targets, such data can be inaccurate and as it is not derived
locally has limited use to inform local decision making.
2.2 For species there is a large variation
in the data collected. Some groups such as birds are regularly
monitored, largely due to volunteer effort, but for other groups
such as invertebrates and some mammals there is no comprehensive
recording system. Local Biodiversity partnerships and or Local
Record Centres do not generally have the resources to undertake
comprehensive surveys of biodiversity species.
2.3 The national biodiversity reporting
system, BARRS, whilst laudable in its intended purposes, requires
significant effort from local biodiversity partnerships, with
very limited benefit locally. ALGE members experience suggests
further development is required before it becomes widely adopted
as an effective means of monitoring the delivery of biodiversity
targets.
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 UK Biodiversity Action Plan has
been successfully in raising the profile of biodiversity and the
natural environment in certain sectors. The system of designating
important sites is also largely effective in preventing harm from
development activities. Protection and enhancement of biodiversity
through the planning and development control process, has also
been made much more possible through the publication of PPS9.
However the effectiveness of PPS9 is not being monitored or checked—in
particular, whether or not its recommendations are being incorporated
into Local Authorities' LDFs.
3.2 The NERC duty for public bodies is a
step in the right direction, but the wording of the duty—"to
have regard to biodiversity" rather than to further the aims/objectives
of the UK BAP—is weak and the duty itself is undefined.
Until recently, the lack of biodiversity performance indicator
for local authorities has influenced the degree to which local
authorities have dealt with biodiversity. Increased effort will
be required to ensure as many authorities as possible adopt the
performance indicator as improved protection and management of
local wildlife sites provide an important mechanism to help deliver
the 2010 target.
3.3 The Entry Level and Higher Level Stewardship
schemes for environmental improvement in the agricultural sector
appear limited in their effectiveness at enhancing biodiversity
in the wider countryside. In part this is an issue about the scale
of funding and targeting, For example, the criteria for ELS are
minimal and whilst a step in he right direction appear unlikely
to make any significant difference to habitat extent in the wider
farmed countryside.
3.4 HLS is largely targeted at SSSIs. In
some parts of lowland Britain such as East Midlands and East of
England there are few SSSIs, and the few that are present are
small and widely dispersed. HLS is having no impact at all on
wider biodiversity in these areas. To do so it will need to be
targeted more widely at habitat networks and Local Wildlife Sites.
3.5 There is no national spatial policy
or plan for biodiversity adaptation to climate change, although
many regions are tackling this. For example, unlike the Netherlands,
we have no defined national habitat network; UK focus is still
on protected sites and species, rather than ecosystems and biodiversity
in the wider landscape.
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 Due to guidance such as PPS9, biodiversity
protection is being incorporated into some local and regional
planning documents, such as LDF core strategies. However, the
linkages with other local plan documents, such as SPDs on employment
land, are still being missed. The manner in which protected species
legislation operates raises questions as to whether the cost benefits
for biodiversity achieved are worthwhile given the scale of resources
currently invested in dealing with protected species affected
by the planning system. Evaluating whether greater benefits from
the investment being spent on dealing with protected species is
urgently required to ascertain whether the potential exists to
deliver greater benefits for biodiversity in the long-term.
4.2 The Ecosystem Approach could potentially
provide benefits for conserving biodiversity as it provides a
means of valuing the natural process occurring in biodiverse landscapes
that benefit society whist recognising the need to conserve biodiversity
for its own sake. However, its adoption into to decision making
may require placing different assumptions on how we determine
conservation priorities in the UK. For example, in large urban
locations, gardens can contribute significantly in supporting
biodiversity but also have the potential to ameliorate the heat
island effect as urban temperatures increase as a result of our
changing climate and can help in absorbing surface water in extreme
events. The Ecosystem Approach should compliment the existing
systems and not be seen as an alternative.
4.3 Progress is being made in ensuring the
value of ecosystem services is reflected in decision making, for
example in Green Infrastructure policies, but progress is slow
and more research into understanding how the approach can be adopted
into policy and practice within central and local government policy
and decision making is urgently required.
KEY THREATS
5. What are the key drivers of biodiversity
loss in the UK, and is the Government addressing them?
5.1 Habitats loss from intensive agriculture
and the use of pesticides and inorganic fertilisers remain a key
driver in causing loss and the ability to recover past losses
in rural areas.
5.2 Local Wildlife sites are key biodiversity
recourse. However they have no legal protection, beyond the limited
protection given in the planning system. Consequently biodiversity
can be lost due to changes in management practices or equally
lack of management over which there is no control. Invasion by
non-native species such as Japanese knotweed and Himalayan balsam
can results in major losses of biodiversity in certain important
localities.
5.3 Although a relative strong policy framework
is in place to address biodiversity loss though the development
regime, the potential for development to deliver significant gains,
regardless of whether a proposal impacts on biodiversity does
not appear to being fully realised Examples where adequate enhancement,
mitigation and compensation for loss has been achieved appear
to be still comparatively rare, and are usually associated with
protected sites and species.
5.4 Small scale developments can have result
in a cumulative loss of local biodiversity, through for example
the loss of small habitats that on their own are not significant
or through the general "tidying-up" of areas such as
the removal areas of scrub or bramble.
5.5 Developments of all scales may also
have indirect impacts on biodiversity that are not fully understood.
The increase in lighting on sites, for example, affects the feeding
of some bat species and other nocturnal feeders.
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 invasion of non-native species is
a major cause of concern. However the Framework will be ineffective
unless adequate resources are made available and responsibility
for tackling outbreaks or co-ordinating joint working is clarified.
There is for example, no single agency is responsible for controlling
the spread of invasive aquatic species such as Floating Pennywort.
6.2 The response time is too slow—for
there to be any chance of eradication following discovery of an
outbreak of an invasive species, action must be swift and intensive
while the species is still relatively contained. Belated action
is likely to be ineffective and possible a waste of resources.
For some species the control effort required is now enormous.
Japanese knotweed, for example is a major problem in many areas
and will require a river catchment approach to eradicate it. In
many areas there are insufficient resources to undertake such
large scale schemes.
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 The impacts of climate change on biodiversity
in the UK are unclear. The most effective means of adapting to
this unknown change will be to increase the amount of land in
the wider countryside managed for nature conservation through
landscape-scale restoration of biodiversity; to identify, conserve,
enhance and create habitat networks; and to address habitat fragmentation
and lack of connectivity.
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 See 3.1 and 5.3 above.
8.2 There can be a conflict between some
planning policies and the need to protect biodiversity. In planning
eco-towns all aspects of sustainable development need to be considered
including impacts on biodiversity, both directly and indirectly.
If such sites are to provide exemplars of sustainable development
they should be setting the standards for development and adopting
emerging policy, for example understanding the contribution ecosystem
services could provide to make them sustainable.
8.3 Greenbelt is a primarily a landscape
designation and does not necessarily include areas of existing
biodiversity value. Areas outside the greenbelt can have higher
biodiversity value than areas within. In addition, biodiversity
is not necessarily protected by current greenbelt policies—for
example, the creation of recreational facilities such as golf-courses
and sports pitches can damage habitats, but are permissible in
green belts. Biodiversity polices and the impact of each potential
development site on biodiversity sites, habitats, networks and
species should be considered alongside greenbelt policies.
8.4 Many post-industrial brownfield sites
have become valuable for biodiversity and development on such
sites can harm wider biodiversity. Guidelines encouraging development
on brownfield sites does risk biodiversity. As above, biodiversity
policies and the impact of each potential development site on
biodiversity sites, habitats, networks and species should be considered
against other policies, and development on these sites should
be careful evaluated where particular important biodiversity resources
occur. In some instances the loss of Greenfield sites to development
maybe preferable for biodiversity than the loss of a Brownfield
site.
8.5 The classification of gardens as "previously
developed" encourages the loss of backland and gardens to
development. This will cause loss of biodiversity, especially
in urban areas where gardens are one of the most important habitat
types. The emerging Greater Manchester Ecological Frameworks has,
for example, identified gardens as a key biodiversity resource.
In parts of the UK, several UK BAP species (House Sparrow, Starling,
Song Thrush, Bullfinch, for example) are associated with large
gardens, and may be threatened by loss to development.
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 Resources are inadequate. Local Biodiversity
Partnerships are key mechanisms to facilitate biodiversity action
on the ground but the vast majority struggle for funding. Although
funding received from Natural England over the last three years
has been a lifeline in England, it has not been sufficient to
fully fund project delivery.
9.2 Local authorities have a key role to
play in biodiversity conservation, but funding for local authorities
to conserve biodiversity on their own land and within their administrative
area often limited, and a number of local authorities still do
not employ biodiversity specialists or have access to expertise.
Biodiversity services within local authorities, being non-statutory,
can be vulnerable to budget-cuts and savings.
9.3 Recent funding cuts and loss of staff
and biodiversity expertise in Government agencies such as Natural
England could have a serious impact on biodiversity conservation
in England.
9.4 Resources are urgently needed to initiate
landscape-scale projects to address climate change adaptation
and biodiversity decline in the wider countryside, especially
in the English lowlands. Currently many such projects are dependant
on an ad hoc regime of grants and complicated partnership funding
arrangements. Their long-term future management must be in doubt.
9.5 Collection of field data and co-ordination
of records is seriously under funded, with many County-based local
records centres struggling to survive and manage data. Recent
funding from Natural England has again been a lifeline but it
is limited in terms of amount and duration; is currently only
available for two years. Field surveys are needed to provide information
for monitoring and to inform decision-making, yet there is no
core funding available to local authorities or other organisations
for doing these.
9.6 The ELS and HLS environmental stewardship
scheme for agricultural land are inadequately funded and appear
to deliver the level of landscape-scale change in the wider countryside
required.
9.7 Local Wildlife Site systems are crucial
components of local biodiversity action plans and spatial strategies
for conservation and climate change adaptation. Local Authorities
have the main responsibility for these systems. Resources to set
up, administer and monitor these systems are not part of LA core
funding, and as a result many systems are under-resourced and
struggling.
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 The current series of statutorily protected
sites and areas is inadequate now, especially in the lowland UK
where SSSIs are generally small and widely dispersed in a sea
of intensively-farmed land of low biodiversity value. This is
partly due to the policy of SSSIs being a representative suite
of habitats, rather than a means of protecting all land of special
biodiversity value. To be effective, protected sites need to have
wide buffer zones and connectivity to a wider habitat network.
10.2 In addition Natural England can be
slow to designate new SSSI, even where existing value has been
demonstrated. Botany Bay Wood in Greater Manchester, for example,
was identified as a potential SSSI prior to 2002 but has yet to
be notified.
10.3 The effect of climate change on SSSIs
provides a significant challenge. Some SSSIs on habitats at the
limit of their range will be especially vulnerable and may not
be sustainable.
10.4 Potentially, the series of non-statutory
protected sites (Local Wildlife Sites) goes some way towards addressing
the issue of biodiversity protection in the wider countryside,
and in buffering and connecting SSSIs. Local Wildlife Sites can
be an effective method of protecting sites in development areas
within the planning process. However, for them to be an effective
method of site protection in the wider countryside, these sites
must be accounted in environmental stewardship schemes, especially
HLS.
10.5 Work is desperately needed to address
fragmentation of habitat, especially in lowland Britain. The expectation
that ELS and HLS would help to deliver landscape change in the
wider countryside has yet to be realised.
2 June 2008
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