Memorandum submitted by the Environment
Agency
1.0 INTRODUCTION
Background
1.1 The Environment Agency welcomes the
opportunity to contribute evidence to this Inquiry. We have an
important role to play in helping Government deliver its international
and national commitments to biodiversity, including the 2010 target
of halting the decline in biodiversity loss.
Our role in biodiversity
1.2 We deliver biodiversity through: (i)
controlling pollution to air, land and water; (ii) regulating
water abstraction; (iii) maintaining and creating wetland habitats
as a result of our flood risk management activities; and (iv)
local partnership projects with fisheries and wildlife organisations[67].
We have a lead role for 39 species and five habitats associated
with water and wetlands under the UK Biodiversity Action Plan
(UKBAP).
1.3 Our evidence concentrates on those questions
where we have a particular mandate.
2.0 A SUMMARY
OF OUR
RESPONSE
2.1 Major advances have been made to protect
biodiversity in the legislative and policy framework, but there
is still a continuing decline in some habitats and species.
2.2 Recent improvements in the condition
of Sites of Special Interest (SSSIs) in England are the result
of co-ordinated action from several sectors, this needs to continue.
2.3 The protection and restoration of designated
sites needs to be accompanied by parallel action to deal with
environmental pressures brought about through increasing pressures
in the wider countryside. This will also reduce the impact of
climate change on the natural world.
2.4 The Biodiversity Action Plan (BAP) process
has been successful in raising biodiversity issues across Government,
getting the business sector engaged and focusing targeted partnership
action towards some high profile species and habitats. It has
been heavy on planning, but, in the absence of adequate funding
and legislative backing, relatively light on action, with a few
notable exceptions.
2.5 An overall biodiversity strategy beyond
2010, setting out clear goals and the wider benefits to society
is needed. Effective legislation and policies, well-targeted incentives
for land mangers and innovative use of major funding sources to
yield multiple benefits will all be needed to implement such a
strategy successfully.
2.6 To improve effectiveness in the future a
clearly focused, properly funded and targeted programme of action
is needed, akin to the successful Public Service Agreements (PSA)
remedies programme for SSSIs. This will ensure that sectors responsible
for action are clearly involved in understanding why and how they
can reallocate resources to help. Government should provide the
lead in the same way as it has done for SSSIs.
3.0 OUR RESPONSE
TO SPECIFIC
QUESTIONS
GOVERNMENT'S
PROGRESS TOWARDS
THE 2010 BIODIVERSITY
TARGET
Is the Government on target to meet its 2010 biodiversity
target?
3.1 Only partly. Prospects are good for
achieving the target for 95% of SSSI land in England to be in
"favourable" or "unfavourable, recovering"
condition by December 2010, although this may be difficult to
achieve for rivers, lakes and wetlands, where the recovery processes
take longer. We are playing a full part, for example contributing
24,637 hectares of SSSI remedies in 2007-08.
3.2 Despite this, the most recent report
on the status of habitats and species of European importance found
in the UK is less encouraging. Only 53% of habitats and 44% of
species are considered to be in favourable or recovering condition
throughout their range[68].
3.3 Overall improvement in air and water
quality over the past two decades in particular has resulted in
some notable examples of species recovery, including the recent
return of salmon to the Mersey, and dolphins and sea-horses to
the Thames estuary. However, habitat fragmentation, diffuse air
and water pollution and the effect of non-native species continue
to threaten a wide variety of vulnerable habitats and species
such as chalk rivers, native white-clawed crayfish and freshwater
pearl mussel.
How effective is the biodiversity monitoring and
reporting process?
3.4 There are some excellent examples of
monitoring and reporting for specific species. The otter population
has been a very effective monitoring tool in tracking their recovery
from pesticide pollution. In England, the presence of otters at
sampling points increased from 5.8% in 1977-79 to 34% in 2000-02[69];
in Wales there was an increase from 20% in 1977-88 to 71% in 2002[70].
National monitoring of breeding and wintering birds and butterflies
that use an "Atlas" approach also provide trend patterns
that policy-makers and the public can easily understand.
Are the biodiversity indicators meaningful?
3.5 The farmland bird index is useful in
highlighting the biodiversity declines of some species caused
by the effects of agricultural intensification. The slow, partial
recovery of farmland bird populations underlines a continuing
need for environmental incentives for farmers to help improve
biodiversity. With the potential loss of set-aside land this recovery
may not continue.
3.6 Environmental monitoring (eg our water
quality monitoring in rivers and estuaries) is an additional indicator
but is not a direct substitute for biodiversity survey data as
a measure of trends in the health of our environment. This applies
particularly to those species which are very vulnerable to changes
in habitat, such as salmon and eels for which we have good information
based on catch returns and fish-counter technology[71].
Is there adequate data upon which to define targets
and assess progress?
3.7 The amount and reliability of biodiversity
data is improving. Local Biological Records Centres and the National
Biodiversity Network (NBN) could play a particularly important
role in protecting the natural environment by providing information
required for planning decision-making, but lack proper support.
3.8 Establishing a realistic baseline is
important. Targets for BAP habitat creation (eg Saltmarsh and
reedbed) are usually based on restoring/preventing the deterioration
of all existing sites and/or restoring a proportion of previous
extent, but the lack of detailed habitat inventories means that
there is often uncertainty over the baseline. The time lag between
taking action and the biological response is also a confounding
factor in determining when a target has been achieved. This is
particularly true for rivers, lakes and wetlands, and the organisms
that are dependent upon them.
3.9 The underlying principle of the WFD
in setting ecological objectives for inland and coastal waters
in response to environmental pressures represents a major change
in the traditional approach to target-setting. Monitoring whether
these ecological objectives are being achieved will be far more
meaningful than before.
Are the policy and institutional frameworks effective
at protecting biodiversity?
3.10 Many organisations contribute to the
delivery of biodiversity protection. Recent legislative changes
notably the Natural Environment and Rural Communities Act 2006
have helped to "raise the bar" by putting a specific
biodiversity duty on Ministers and statutory organisations, including
local government. However, such organisations often lack the resources,
guidance, information and expertise to undertake these duties
properly.
3.11 Private organisations also have a role
to play. The national environment programme within the Periodic
Review of Water Prices has been a powerful policy lever for securing
investment by water companies. During 2000-10 almost £1 billion
will have been spent investigating and tackling problems related
to damage caused by water abstractions and pollution.
3.12 Over 1,700 kilometres of river and
150 wetlands of European and national importance have benefited
from this investment and the work has been heavily influenced
by our Review of Consents programme for the Habitats Directive
and the SSSI remedy programme in England. We will be pushing for
further improvement work as part of the next Review period, covering
2010-15.
3.13 The Marine Bill should help to address
current shortcomings in legislation protecting marine biodiversity.
Is biodiversity addressed effectively at local
and regional levels?
3.14 Implementation of Regional and Local
BAP strategies is constrained by insufficient funding. The recent
inclusion of biodiversity duties on local planning authorities
has been a welcome move, but they are not effectively resourced
to carry this out.
3.15 The link between Regional Spatial and
BAP Strategies provides a considerable opportunity to improve
action for biodiversity, particularly now that most Regions have
produced nature maps that show not only the existing resource
but also areas where there are opportunities for improvement.
3.16 Under the WFD, River Basin Liaison
Panels that advise on the 11 river basin district plans in England
and Wales provide a good opportunity for co-ordinating national
measures and local action for improved ecology in river catchments
and coastal waters. We have played our part in local initiatives
to improve biodiversity. In the last five years we have taken
part in 1,600 biodiversity projects. More than 1,700ha of habitat
has been created and £112 million of partnership money spent.
How successful has the UK Biodiversity Action
Plan been?
3.17 It has successfully raised the profile
of biodiversity by identifying priorities and providing the basis
for quasi-legal protection of a large number of hitherto unprotected
species.
3.18 It has galvanised support and provided
a recognisable business-like focus for those inside and more importantly
outside the biodiversity profession. However, the effort invested
in developing species and habitat action plans has not always
been matched by action, mainly due to a lack of available resources.
3.19 Because the UKBAP was never a fully-funded
implementation programme, it relies disproportionately on "voluntary"
contributions. The £300 million funding gap identified by
the RSPB[72]
means that better ways of using existing budgets to benefit biodiversity
are needed.
Does "Conserving biodiversity—the UK
approach" address the need to have a joined up approach to
biodiversity protection with the devolved administrations?
3.20 It sets out a compelling case for sustaining
biodiversity across the UK, particularly in the context of climate
change. The marine environment is probably the best example for
underlying principles to be applied across all the administrations.
3.21 Devolution and the development of separate
country groups for England, Scotland, Wales and Northern Ireland
has introduced a more complicated UKBAP process, but responsibility
for delivery has been placed much closer to source. Similarly,
there are timescale differences between England and Wales for
achieving favourable or recovering condition of SSSIs (2010 and
2015).
How well is biodiversity protection incorporated
into the policy-making process?
3.22 Within Defra and the wider Defra family
(including Natural England, Environment Agency and Forestry Commission)
biodiversity is now well incorporated into policy-making.
3.23 Linked to this, specific operational
targets for biodiversity improvements and gain now appear in the
corporate plans for relevant delivery agencies such as ourselves.
How well will the Ecosystem Approach Action Plan
address this issue?
3.24 The Action Plan clearly demonstrates
why maintaining or restoring functioning ecosystems is important
in securing socio-economic and biodiversity benefits in the longer-term.
3.25 However getting the approach understood
and adopted by non-specialists will mean using simple language
and specific high-impact examples. Current terminology is too
technical and abstract for most people to understand.
KEY THREATS
What are the key drivers of biodiversity loss
in the UK and is the Government tackling them?
3.26 Habitat fragmentation and loss, diffuse
air and water pollution, over-exploitation of resources (eg water
abstraction, mineral extraction, over-fishing) and the impact
of non-native species are all critical threats. Sometimes these
threats interact and are amplified by the effects of climate change,
for example excessive sedimentation caused by the loss of soils
to rivers and lakes during intense storms, and resultant eutrophication.
The loss of non-rotational set-aside is an added, recent threat.
The UKBAP and the emerging River Basin Plans[73]
flag threats relating to specific species and/or areas of the
country.
3.27 As historical problems, such as poor
water quality, have been tackled others (particularly urban and
rural diffuse pollution, agricultural intensification, increasing
development pressure) have a proportionately larger impact. The
response needs to be a combination of new voluntary action facilitated
by education and advice, legislation and powers, strategic planning
and economic incentives.
Will the Invasive Non-native Species Framework
Strategy prove effective?
3.28 The Framework Strategy provides much-needed
clarity and a clear basis for co-ordinated action to tackle the
most important priorities. The various working groups already
established have helped to focus attention on the highest threats,
encouraged swift and co-ordinated effort and improved public awareness.
Is there adequate regulation and resources to
prevent further invasions and to undertake eradication programmes?
3.29 New Regulations and proposals for further
restrictions (eg ban on sale of the most pernicious species; new
fisheries legislation on the Aquatic Animal Health Directive and
Alien Species Regulations) together with high profile campaigns
(such as that run by the Cornwall Knotweed Forum) should help
to reduce the risk of deliberate or accidental introductions.
3.30 A costed implementation plan setting
out who is responsible for doing what in the GB strategy is needed.
The single biggest constraint is adequate resourcing for action
and research.
What impact will climate change have on UK biodiversity?
How might the impacts of climate change be reduced?
3.31 Generic impacts and changes that are
already happening are well catalogued[74],[75],
although there is still uncertainty about the response of individual
species.
3.32 Short-term impacts can be managed by
(i) reducing existing pressures such as pollution, over-exploitation
of natural resources, and unsustainable land-use (ii) habitat
fragmentation can be addressed by creating and expanding ecological
networks. Protected sites should be restored and maintained as
relatively unimpacted core refuge areas in the landscape to allow
plants and animals to maintain their distribution or move in response
to climatic change.
How can the potential conflict between climate
change mitigation and adaptation measures and biodiversity protection
be effectively managed?
3.33 A Strategic Environmental Assessment
approach across inter-dependent policy sectors (eg energy, transport,
housing, biodiversity) is essential to avoid problems such as
those associated with bio-fuels.
3.34 The hierarchical principles of avoiding
damage, minimising unavoidable harm, restoring damage caused,
and mitigating/offsetting residual loss need to be applied to
protect biodiversity.
Does planning policy adequately protect biodiversity?
3.35 A key planning objective in PPS9 is
"to conserve, enhance and restore the diversity of England's
wildlife and geology by sustaining, and where possible improving,
the quality and extent of natural habitat". It is widely
acknowledged by nature conservation organisations that planning
policy is particularly effective in protecting internationally
and nationally important habitats and species, but is less effective
for non-statutory local wildlife sites. Such sites and species
need stronger protection through planning policy.
Are effective measures in place to ensure that
Government plans for housing growth (including eco-towns) enhance
rather than damage biodiversity?
3.36 It is unclear whether biodiversity
will be effectively safeguarded under the new plans as many are
in very early stages of development. The Environment Agency along
with Natural England is advising on growth points and eco-towns.
In some cases new growth points, eco-towns or other new housing
will be proposed for greenfield areas with little or no biodiversity
interest, and this represents a significant opportunity to enhance
biodiversity overall as part of the housing or new community design—for
example "green grids" proposed in parts of the Thames
Gateway.
RESOURCES
Are there adequate resources for biodiversity
protection and enhancement?
3.37 There is insufficient money to help
safeguard and enhance populations of European Protected Species,
local wildlife sites, BAP priority habitats and species elsewhere.
This gap needs to be addressed because local wildlife sites in
particular will be increasingly important refuges in an adaptation
strategy for climate change. Better and more targeted use of agriculture
funding, particularly shifting funds from Pillar 1 to Pillar 2
for CAP[76]
could and should be a key lever in closing the current funding
gap.
PROTECTED AREAS
Is the UK protected area network up to the job
of maintaining biodiversity, now and into the future?
3.38 For internationally and nationally
important terrestrial habitats and species the current network
is adequate although more action is still required to improve
and maintain site condition. As our knowledge of climate change
improves, designation criteria and the adequacy of the existing
network may need to be reviewed. Designation of Marine Protected
Areas will belatedly help to plug a large gap in the protected
area network.
Are arrangements to protect sites effective?
3.39 The condition of SSSIs in England has
improved dramatically in the past 5 years following the introduction
of a coordinated and targeted remedial work programme. A similar
programme is now being implemented in Wales.
3.40 Some outstanding legislative and policy
blockages still need to be resolved, such as tackling Common Land;
powers and resources needed to deal with diffuse pollution from
agriculture and adequate resourcing of measures.
Is more work needed to reduce habitat fragmentation
and to link up those semi-natural habitat areas that remain?
3.41 Yes. This is the single biggest challenge
and one that will make or break the climate change adaptation
strategy in relation to biodiversity in protected sites and beyond.
3.42 An overall strategy is needed, underpinned
by good science, practical experience and economic incentives
for those affected. As many organisations will be involved, clear
leadership and adequate resources are essential to coordinate
a programme of action that will transcend environmental, agricultural,
development and climate change policy areas.
3.43 Strategic planning tools such as the
Wetland Vision for England[77],
and practical on-the-ground examples (eg the Great Fen project)
can demonstrate how theory can be put into practice. The biggest
challenge remains availability of funding. This will only be freed
up if policy and decision-makers in other sectors are convinced
about the benefits of building biodiversity into their plans and
projects.
6 June 2008
67 Creating a Better Place for Wildlife: how our
work helps biodiversity: (2006) Environment Agency Back
68
2nd UK report on implementation of the Habitats Directive (article
17 report), Joint Nature Conservation Committee (2007). Back
69
Fourth Otter Survey of England, Environment Agency (2003). Back
70
Otter Survey of Wales, Environment Agency (2004). Back
71
The annual assessment of salmon stocks and fisheries in England
and Wales 2007, Environment Agency (2008). Back
72
RSPB press release: http://www.rspb.org.uk/news/details.asp?id=tcm:9-183730 Back
73
Significant Water Management Issues have been identified for each
River Basin District. Back
74
Ecos, 28, 1079 (2007) Climate chaos-helping nature cope. Back
75
MONARCH, a synthesis for biodiversity conservation, UKCIP (2007) Back
76
Beyond the Pillars: Wildlife and Countryside Link's policy perspective
on the future of the CAP, March 2008 Back
77
Wetland Vision web-site: http://www.wetlandvision.org.uk/ Back
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