Memorandum submitted by The Wildlife Trusts
INTRODUCTION
1. The Wildlife Trusts welcome this opportunity
to submit evidence to the Environmental Audit Committee to inform
the inquiry into protecting biodiversity in a changing Britain.
2. There are 47 local Wildlife Trusts across
the whole of the UK. We are working for an environment rich in
wildlife for everyone. With 765,000 members, we are the largest
UK voluntary organisation dedicated to conserving the full range
of the UK's habitats and species whether they be in the countryside,
in cities or at sea. We manage 2,200 nature reserves covering
more than 80,000 hectares; we stand up for wildlife; we inspire
people about the natural world and we foster sustainable living.
www.wildlifetrusts.org
3. Given our extensive engagement at all
levels of the BAP process we are well placed to respond to this
inquiry. At a UK and national level, we represent The Wildlife
Trusts on the UK Biodiversity Partnership Standing Committee,
the England Biodiversity Group and a wealth of other country/specialist
groups including the Wildlife and Countryside Link Biodiversity
Group. Through our roles as lead partner for a number of BAP species,
Chairing Regional Biodiversity Forums and hosting a significant
number of Local Biodiversity Action Plan coordinators coupled
with our engagement in virtually all LBAP processes we contribute
significantly to both the strategic action planning and direct
conservation of the UK's biodiversity. Locally, Trusts are also
engaged in 146 Local Strategic Partnerships and more than 62 Local
Site partnerships. In both cases, they take a leading role in
more than 25% of these.
4. The Wildlife Trusts recognise that the
pressures upon our wildlife have continued to increase and realise
the ramifications of climate change could be catastrophic for
UK biodiversity. In order to avoid the large-scale biodiversity
losses that climate change could cause in the UK, we believe the
future of wildlife conservation is through taking a landscape-scale
approach. To this end The Wildlife Trusts have developed A Living
Landscape, an aspirational but realistic vision for biodiversity
conservation (attached).[3]
We are involved in more than 100 Living Landscape schemes across
the UK and want to see policy, incentives and regulation to support
their delivery. By rehabilitating degraded habitats and greenspaces
in town and countryside we can reconnect the remaining biodiverse
hotspots scattered across the UK, creating a dynamic landscape
capable of supporting the changes wrought by climate change.
5. The Wildlife Trusts are also aware of
the increasing demands being placed on our marine environment
through over fishing, development and climate change. Marine conservation
within the UK is decades behind our terrestrial approach with
only 0.001% of our seas being highly protected. We are calling
upon the UK Government and devolved administrations to publish
a Marine Bill which will ensure that an ecologically coherent
network of Marine Protected Areas are designated. In order to
fulfil the UK's international commitments and achieve the Government's
vision of clean, healthy, productive and biologically diverse
oceans and seas, it is necessary to designate more than just a
handful of small, isolated sites. Rather, the aim must be to build
a wide-ranging network of sites that represents the full range
of habitats and wildlife in our seas. For the network of sites
to be ecologically functional, it must be designed to provide
connectivity between sites—in other words, MCZs must be
an appropriate distance apart to facilitate movement of larvae
(and in some cases adults) between sites. This will allow the
sites to support each other, as well as helping to replenish the
wider sea.
6. While our response to this inquiry is
focused primarily on policy in England, the principles are common
throughout the UK.
SUMMARY
7. The Wildlife Trusts are concerned Government
is not on course to meet its target of halting biodiversity loss
in the UK by 2010. We believe the natural environment needs to
be an underpinning feature across all Government departments and
that a landscape scale approach to conservation should be adopted.
While Defra has taken positive steps to address landscape scale
conservation through its work on ecosystems, we are concerned
the same commitment is not being recognised or addressed across
other departments and broader policy. We want to see a fundamental
shift across government to recognise the importance of the natural
environment to our quality of life and in our response to climate
change. The Wildlife Trusts believe the natural environment should
be at the heart of the UK's climate change adaptation framework.
GENERAL COMMENTS
Biodiversity Trends
8. Whilst certain priority species have
seen modest increases in population size, and in some cases have
successfully expanded their geographic range (e.g: otter Lutra
lutra and bittern Bottaurus stellaris), The Wildlife Trusts are
concerned that we are still seeing significant declines in biodiversity.
Since 1997 the number of species targeted for conservation action
by the UK Biodiversity Action Plan has more than doubled from
577 to 1,149. Furthermore, declines are not just limited to rare
species. Increasingly we are seeing a decline in scarce species
at a county level, which won't necessarily be picked up by national
monitoring measures.
9. In addition, the range and extent of
natural habitats within the UK continues to decline, with remnant
areas experiencing fragmentation and isolation to such a degree
that their long term viability cannot be assured.
Monitoring
10. The effectiveness of biodiversity monitoring
varies across the UK, affected by the availability of baseline
data, resources and the processes used. Currently monitoring systems
are not integrated, making it difficult to achieve a comprehensive
picture of the changing state of biodiversity in the UK. At present
there are a number of systems which do not necessarily or consistently
feed into one another. For example the National Biodiversity Network
(NBN), Local Records Centres, LBAP monitoring via BARS, the Observatory
Programme launched by Defra. This can result in a misrepresentation
of the UK's biodiversity status.
11. We believe there needs to be comprehensive
UK coverage of Local Records Centres supported by a sustained
allocation of resources, coupled with the introduction of standard
methods aimed at simplifying and encouraging regular reporting.
12. Habitat opportunity maps can provide
local, regional and national government with vital information
to support a robust, climate-proof, long term, landscape-scale
vision for the benefit of biodiversity, people and the economy.
The Wildlife Trusts believe we should take this spatial approach
to demonstrate our aspirations and ensure it is imbedded within
planning policy and decisions.
13. With existing biodiversity indicators
being heavily biased towards rural species and communities, their
use as a tool for measuring relative gains and losses is limited.
We want to see the development of indicators which provide more
comprehensive measures. In particular, we believe completing the
habitat connectivity-index indicator is an urgent priority.
14. We were pleased to see the inclusion
of National Indicator 197:Improved local biodiversity through
the positive management of Local Sites, within the national suite
of indicators for local authorities and their partners. Through
our experience of engaging with, and influencing Local Area Agreements
we know how important this indicator could be in focusing resource
and effort on improving biodiversity. We now want to see it recognised
and promoted nationally and through the regions as a priority
for inclusion within Local Area Agreements.
Factors contributing to biodiversity loss
15. The pressures causing or contributing
to biodiversity losses in the UK are extensive. The impact of
these pressures is resulting in habitat destruction, degradation
of quality, and isolation of remnant areas.
Agriculture
16. In 2000, over 75% of land in the UK
was dedicated to agricultural production. Across the EU, farmland
supports over 120 vertebrate species of European Conservation
Concern, a number significantly higher than any other habitat,
highlighting both the conservation importance of the land and
the vulnerability of these species. The industrialisation of agriculture
had a universally detrimental impact upon ecological interactions,
with few fragmented areas of good quality habitat surviving. The
Wildlife Trusts recognise the efforts made by the Government to
increase ecological diversity on farmland, but believe the following
concerns need to be addressed:
— There is insufficient resource. There
needs to be further reform of the Common Agricultural Policy (CAP)
with modulation from Pillar 1 to Pillar 2 to support agri-environment
measures.
— Cross compliance and Entry Level
Stewardship measures need to be revised to provide increased connectivity
and permeability, in particular to compensate for loss of set
aside.
— Higher Level Stewardship (HLS) is
currently being used to deliver too many objectives, with the
result it now focuses primarily on the maintenance of existing
habitat.
— HLS targeting needs to prioritise
Local Wildlife Sites and habitat restoration schemes to ensure
it supports biodiversity need.
— Currently there is a missing mechanism
within land management schemes that prioritises restoration and
re-creation of the natural environment.
— In the current climate of high-commodity
prices, pressures on land use for food and fuel will be intense
and agri-environment will need to be modified to ensure it provides
an attractive and competitive business option for farmers.
17. Further policy recommendations for biodiversity
in agriculture are outlined in the attached Wildlife and Countryside
Link report: Beyond the Pillars.
Development
18. Inappropriate and unsympathetic development
continues to place pressure upon biodiversity. The Wildlife Trusts
do not consider growth and conservation to be mutually exclusive.
However, the benefits of ecosystem services are generally undervalued
and misunderstood by planners and unfortunately there is nothing
enshrined in planning policy to encourage decision makers to consider
the worth of biodiversity in terms of maintaining ecosystem services.
We believe the planning system should ensure all new development
is environmentally sustainable and delivers gains for biodiversity.
19. Recently the Natural Environment and
Rural Communities (NERC) Act 2006 placed a further statutory responsibility
upon local authorities to place biodiversity conservation and
enhancement at the heart of decision making. In reality, the effective
implementation of this and other policies varies dramatically
between local authorities, with biodiversity protection still
generally perceived as a peripheral "box-ticking exercise"
as opposed to an integral aspect of modern land-use planning.
Many local planning authorities lack in-house ecological expertise
and planners do not necessarily possess the skills to make sound
ecological judgements. Furthermore, pressure to meet Government
targets can impose unrealistic timescales to make decisions, resulting
in opportunities to secure biodiversity enhancement and re-creation
being overlooked.
20. The Wildlife Trusts are concerned that
the Government's current house building programme could result
in further degradation to wildlife. There is no precedent of ecological
excellence in development design and delivery, and therefore we
cannot be confident that this round of housing growth will raise
the bar. The focus for new development is very much upon climate
change mitigation, with ecological impacts featuring low on the
agenda as an optional extra. For example, the Code for Sustainable
Homes does not have a mandatory requirement covering biodiversity.
21. High quality green infrastructure could
have a significant positive impact on biodiversity by ensuring
new developments are permeable to wildlife rather than presenting
an insurmountable barrier. However, as green infrastructure is
not currently established as a mandatory planning requirement
in new development, its true potential is not being realised.
22. Preferential optioning of brownfield
sites for development is causing damage to urban biodiversity
interests. Many derelict brownfield sites exhibit high biological
diversity of both rare and common species, while mature gardens
offer wildlife havens and extensive functional connectivity. The
Wildlife Trusts are concerned about the cumulative loss of biodiversity
and connectivity as a result of the increased pressure from infill
development and we believe gardens should be delisted from the
definition of brownfield sites. We also want to see all proposed
developments on brownfield sites assessed against criteria which
include direct and indirect biodiversity impacts.
23. Our specific policy recommendations
for biodiversity in planning are outlined in the attached briefings
on Eco-towns,[4]
the Sub-National Review, the Planning Bill, and Protected Areas.
Threats to the Marine environment
24. The UK's marine environment is currently
over-exploited and under-managed. Despite having a suite of targets
in place for the marine environment we are still failing to meet
them. In 2005, human activity was acknowledged as being the prime
cause for adverse changes in marine life[5],
which continues to be the case today. Whilst many thousands of
animal and plant species are found here, these species, and their
habitats, are poorly protected, facing significant threats from
over-fishing, pollution, habitat destruction, offshore development
and climate change. These all pose a real threat to the balance
and integrity of the marine ecosystem.
25. The marine environment is not sustainably
managed at present, and the need for a new approach is urgent.
The Wildlife Trusts want to see a Marine Bill which provides an
opportunity to bridge the gap between the protection of wildlife
on land and at sea, and to bring greater coherence to the planning
of the many activities which take place in the marine environment.
We believe the Bill should provide a coherent legislative framework
to deliver the Government's stated goal of "clean, healthy,
safe, productive and biologically diverse oceans and seas"[6].
This framework should be delivered through an ecosystem-based
approach, placing the environment at the heart of the management
of marine activities. This new approach, underpinned by the precautionary
principle, must be based on an explicit recognition of the services
provided by healthy marine ecosystems, including many direct economic
and social benefits.
26. We welcome the Government's continuing
commitment to a Marine Bill, and the wide-ranging scope of the
current draft Bill. While we support the general thrust and content
of the draft Bill, we have some significant concerns that parts
of it (especially section 4 on Marine Conservation Zones), are
weak and if left unchanged may mean the UK Government will fail
to achieve its objectives for nature conservation.
Climate Change
27. The rapid changes in climatic conditions
will have an enormous impact upon UK biodiversity as the speed
with which environmental changes occur will outpace ecological
adaptation. We therefore believe it is essential that the natural
environment is placed at the heart of the UK Climate Change adaptation
framework to ensure its importance is recognised throughout government.
28. We also want to ensure biodiversity
is enshrined within the new duty introduced by the climate change
Bill requiring local authorities to take account of climate change
adaptation and mitigation within Local Development Frameworks.
29. Invasive, non-native species have had
a marked impact upon UK biodiversity, and many resources have
been dedicated to controlling their spread and limiting their
effects upon our ecosystems. There is a need to differentiate
between natural invasions occurring as a result of climate change
and those introductions mediated by humans. In order to prioritise
action against invasive non-natives a measure of the predicted
long term impact of these species upon ecosystem function should
be balanced against the potential cost and scale of effort required
for control or eradication. We believe action should be targeted
on those invasive non-native species where there is the highest
risk, for example aquatic invasive plants.
30. We are already witnessing changes in
the marine environment arising from climate change and further
changes are expected. For example sea temperatures are rising
and the distribution of plankton species is changing. The oceans'
phytoplankton is estimated to absorb about half of the CO2 generated
by humans, making our seas as important as rainforests in mitigating
climate change impacts. Thus, we strongly believe climate change
makes the protection of marine biodiversity and its sustainable
management even more critical.
Conservation strategies and resources
31. The problem we face with the historic
approach to conservation is that designation, management and support
have all been focused on a site based approach. While these sites
and their protection will be essential components of future adaptation
for the natural environment they will not be sufficient to maintain
biodiversity into the future. We believe future policy must be
formed on wider landscape issues to ensure long-term viability
of our natural environment.
32. The focus of conservation efforts must
be upon re-establishing a network of high quality, functional
and robust habitat corridors across the landscape, reconnecting
the disjointed and heavily fragmented biodiverse islands that
constitute the current system of protected sites, and enable a
flow of species movement and migration across the country. This
aim is encapsulated by The Wildlife Trusts visionary document,
A Living Landscape.
33. The Wildlife Trusts own and/or manage
circa 700 Sites of Special Scientific Interest of which 80% are
now in favourable condition. To date, funding for protected sites
has been predominantly targeted at bringing these sites up to
a favourable level. We now need to see funds targeted at maintaining
these sites and to support our response to macro landscape issues
such as coastal squeeze, upland management and diffuse pollution,
so we can bring the remaining 20% into favourable status and ensure
their sustained management for the future.
34. Funding is also needed to support the
protection and management of the UK's non-statutory Local Sites.
The Wildlife Trusts Survey of Local Site systems in England (2007)
showed there are more than 38,000 Local Sites providing wildlife
havens and connectivity across the country. This, and earlier
surveys by The Wildlife Trusts have all shown lack of funding
coupled with the relatively small and easily overturned protection
afforded to Local Sites through the planning system are perpetuating
the trends of loss and degradation inflicted on Local Sites over
recent years. For example between 35% of Nottinghamshire's Local
Wildlife Sites were severely degraded or lost between 1994 and
2004.
35. The Wildlife Trusts firmly support Government
proposals for introducing Marine Conservation Zones (MCZs) and
urge new laws to be introduced without delay. These areas will
supplement internationally important sites protected under EU
legislation and underpin resilient, functioning marine ecosystems
by enabling habitats and wildlife to recover to a near-natural
state. Highly Protected Marine Reserves (HPMRs), within the MCZs
will act as control sites, helping us to understand the impacts
of human activities in the marine environment. In 2001, 160 of
the world's foremost marine scientists stated that HPMRs result
in "long-lasting and often rapid increases in the abundance,
diversity and productivity of marine organisms" and "full
protection (which usually requires adequate enforcement and public
involvement" is critical to achieve the full range of benefits."][7]
We consider the Marine Bill will have failed if it does not lead
to the designation of a suite of HPMRs within the network of Marine
Conservation Zones.
36. A review of the green belt policy has
the potential to provide improved benefits for biodiversity. The
Wildlife Trusts would recommend that such a review is carried
out but done so in light of adaptation policy and habitat opportunity
mapping.
37. Government public sector funding for
biodiversity peaked in 2005-06 at £397 million, a real-term
increase of 50% over 2000-01 expenditure[8].
38. While not necessarily competitive in
the current climate, there is some funding available for biodiversity.
However we believe further opportunities should be harnessed for
restoration and re-creation. For example:
— Further modulation should be introduced
through the CAP health check to provide sufficient funds for ongoing
agri-environment support.
— Increased funds should be targeted
to biodiversity conservation through mechanisms such as the "Community
Infrastructure Levy" and "flood risk management"
with the focus on delivering green infrastructure.
— With the UK climate change adaptation
framework providing a key driver for land use policy. We believe
new funding instruments focusing on restoration and recreation
of the natural environment should be central to this.
39. The Wildlife Trusts believe that without
integrated partnership working across agencies and NGOs biodiversity
gains will not be achieved in proportion with expenditure.
30 April 2008
3 Not printed. Back
4
Not printed. Back
5
Charting Progress, An Integrated Assessment of the State of UK
Seas, Defra, 2005 Back
6
Safeguarding Our Seas, A Strategy for the Conservation and Sustainable
Development of our Marine Environment, Defra, 2002 Back
7
Scientific Consensus Statement on Marine Reserves and Marine Protected
Areas. National Center for Ecological Analysis and Synthesis,
2006 Back
8
Expenditure on Biodiversity in the UK, Defra, 2005 Back
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