Memorandum 3
Submission from the Royal Society for
the Protection of Birds
SUMMARY
1. Sites of Special Scientific Interest
(SSSIs) form the backbone of biodiversity conservation and recovery
in the UK. In underpinning the Natura 2000 network of Special
Protection Areas (SPAs) and Special Areas of Conservation (SACs)
they are central to delivering the objective of the EU's Birds
and Habitats Directives of restoring and maintaining species and
habitats of European importance to a favourable conservation status.
2. A sound scientific evidence base laid
the foundation for the SSSI system and continues to be key to
the proper functioning of the system, informing site identification
and notification, management and monitoring. Going forward it
is vital that this be sustained, as it will be critical in enabling
us to increase the resilience of the individual designated sites
and the network as a whole to a range of pressures, including
those associated with climate change.
THE RSPB: SCIENCE
AND SSSIS
3. The RSPB is a science-based organisation,
and makes significant investment in both primary survey and ecological
research, the results of which are peer-reviewed and published.
This informs our conservation advice and advocacy work, and the
management of our 207 reserves (many of which are SSSIs).
4. Often working with others including Natural
England and the British Trust for Ornithology, the RSPB is a major
contributor to the evidence base upon which the SSSI system relies
(for example through the Wetland Bird Survey (WeBS) and the Scarce
and Rare Breeding Birds Survey (SCARABBS)).
SSSI IDENTIFICATION
AND NOTIFICATION
5. High quality survey data at both the
broad and site-specific levels are essential to the identification
of potential SSSIs, and to the development of a robust scientific
case to underpin notification/renotification of these sites.
6. As declines continue in the wider countryside,
the SSSI network has become increasingly important, and the RSPB
is concerned that the SSSI network remains incomplete. In addition,
some 60% of SSSIs were first recognised as important 20-60 years
ago, and so periodic review and update of the current suite of
SSSIs is required.[19]
7. There has been a failure to undertake
systematic review of the SSSI series in the context of the coherence
of the network, and in recent years, (re)notifications have been
made only on an ad hoc basis, generally in response to development
threats.
8. In addition, a failure to review and
(where appropriate) update the 1989 SSSI selection guidelines
means that the increasing rarity and reliance of some features
on SSSIs over time (eg breeding waders), and enhanced scientific
understanding of ecosystem dynamics, have not been reflected,
and thus not targeted through notification or subsequent management
and monitoring.
9. Consistent with these issues, has been
a reduction in site-specific survey to inform site notification
and review. Substantial investment in survey in the past has provided
a strong scientific basis for the SSSI system, but this must be
sustained to facilitate the completion and periodic review of
the network.
SSSI MONITORING AND
MANAGEMENT
10. For birds in particular, it is essential
that agreed SSSI conservation objectives reflect the need for
an intelligent link between the birds and the habitats upon which
they rely. For example, significant changes in migratory populations
present on a given site between years may be due to either on-site
factors, or to factors affecting migration or sites used at other
times of year. In other words, it is essential that conservation
objectives address bird populations in the context of their ecological
requirements, and that monitoring is effective in measuring relevant
parameters to highlight concerns early on, in allowing differentiation
between on and off-site issues, and in triggering effective action
where required.
11. Common Standards Monitoring (CSM) introduced
standard guidance on Conservation Objectives and SSSI condition
assessment. More recently, the Government's PSA target for SSSIs
(95% of all SSSI land in England to be in favourable or recovering
condition by 2010) has resulted in the introduction of a clear
mechanism to ensure that unfavourable assessments trigger remedial
action ("remedies"). This is most welcome.
12. However, CSM for birds is insufficiently
sensitive to changes in populations, only triggering unfavourable
status when declines of 25% (breeding) or 50% (wintering) or more
are observed: this means that early and cost-effective intervention
to avoid deterioration is not facilitated by the current system.
In addition, CSM for birds makes no assessment of habitat quality,
which is essential for intelligent analysis of bird population
changes at site level.
13. Furthermore, while some sites are covered
by adequate and coordinated bird survey programmes (eg Wetland
Birds Survey), recommended minimum accepted levels of site based
monitoring under CSM for birds (counts from three relevant seasons
in a six year reporting cycle) are inadequate to accurately assess
population levels.
14. These issues highlight the importance
both of strategic and sustained survey and monitoring effort to
underpin effective condition assessment, and the maintenance of
appropriate ecological expertise amongst the conservation agency
staff who are required to make assessments on the basis of limited
information.
15. Finally, it is important to note that
most progress towards the PSA target been made in the transition
of large areas from "unfavourable" to "unfavourable
recovering" condition, triggered by the introduction of management
intended to address the causes of unfavourable condition.
Whilst the PSA target of 95% of all SSSI land
in England to be in favourable or unfavourable recovering condition
by 2010 will be met, so far the attainment of favourable
condition has remained roughly static at around 45%. Thus as we
move to 2010 and beyond, effort must be sustained to attain
real delivery in terms of favourable condition. A sound scientific
understanding of the causes of unfavourable condition and the
efficacy of management measures will be key to assessing the extent
to which measures now in place will deliver the desired results,
and to re-focus action where the present measured are found to
be ineffective, It is clear that greater investment in science
to "crack" particular issues (eg the effects and management
of diffuse pollution in fresh water ecosystems) will be necessary
along the way.
THE FUTURE
16. Building resilience through in situ
conservation is essential: tomorrow's biodiversity will come from
today's. In the face of climate change, the function of individual
sites within the SSSI network and the species they support may
change, but it will be essential that the integrity and coherence
of the SSSI network is maintained.
17. In this context, the need for science
to ensure that SSSIs are fit for purpose, effectively monitored
and successfully managed will become increasingly important. These
sites and our understanding of their role within the wider environment
will be key to sustaining vulnerable populations by building their
resilience to the impacts of climate change in situ, while
also taking action to accommodate and facilitate species range
shifts.
18. We welcome Natural England's recent
notification strategy that commits to strategic and science-based
review of the SSSI network, acknowledges associated data needs
and the potential need for additions/amendments to the SSSI selection
guidelines. However, we are concerned that, with the passing of
the 2010 deadline for the SSSI PSA target, momentum to monitor,
maintain and restore sites to favourable condition may be lost,
just when it is most needed to ensure that the hard work to date
translates into real change.
June 2009
19 National Audit Office. 2008. "Natural England's
Role in Improving Sites of Special Scientific Interest". Back
| 
