Examination of Witnesses (Questions 20-39)
BRIAN EVERSHAM,
ANDREW STOTT
AND ANDREW
CLARK
17 JUNE 2009
Q20 Mr Boswell: Are the incentive
schemes sufficient and effective?
Mr Clark: In most part the incentive
schemes were effective, certainly in the wider countryside. I
think there have been some frustrations in the last three or four
years with the higher level scheme which is particularly targeted
on Sites of Special Scientific Interest. There is rather a stop/go
feeling about whether this high level scheme is going to be available
to all those who own and manage SSSIs and whether the funding
will be available to put in place the right sort of management.
Q21 Dr Harris: I just want to come
back partly to the first question and partly following that. As
I understand it the JNCC produce guidelines under which Natural
England decide what should be proposed as SSSIs and then they
go through a consultation process. Is that correct?
Mr Stott: That is correct.
Q22 Dr Harris: If you look at post-guideline
notifications—if we looked at them now—would there
be a way of predicting which sites have been designated because
it is obvious that they fulfil certain criteria or is it more
of an art than a science in respect of the whole process?
Mr Stott: It is a combination
of both. It is based on the evidence for what features are on
the site matched against the guidelines. Looking back over quite
a long period of time the quality of the evidence is not perfect;
there are not complete surveys of all the features or all the
habitats and therefore there has to be an element of judgment
in relation to the quality of that evidence and its interpretation.
Q23 Dr Harris: As far as you know
there has never been an independent or blinded evaluation of whether
Natural England's decisions are rational even in the context of
the variable amount of evidence that might exist over time. In
other words, if you took the names off and someone independent
came and looked at something that had the designated with the
evidence, that exercise has never been done.
Mr Stott: I am not aware that
exercise has been done but there are some comparative studies
which would track trends within protected sites versus wider countryside.
Q24 Dr Harris: Do you see merit in
there being some limited exercise, a check so that the public
can have confidence that the outcome of the system is rational?
Or is it enough to have the process as it is now?
Mr Stott: I think the process
is quite robust.
Q25 Dr Harris: Finally on that, after
you produce your guidelines, Natural England make propositions
and presumably at some point there is lobbying of Natural England
by people who say yes or no to this proposition. Are you concerned
that that might be over-influential to Natural England who make
these decisions based on the strength of the lobbying campaign
for or against which is not necessarily related to the strength
of the argument in ecological or scientific terms?
Mr Stott: I do not have a concern
about that and it is not really a responsibility of JNCC because
it is the country agencies that have the responsibility to make
the judgement based on the best science. Our responsibility is
to provide guidance.
Q26 Dr Harris: Mr Eversham, do you
have anything to say on that?
Mr Eversham: I think we can help
you out with your idea about objectivity. We have not done a blind
analysis, I must admit, but having surveyed something like 4000
wildlife sites across my three counties over the last decade and
evaluated each of those according to quantitative criteria mostly
based on plant species, so if it is a chalk grass, then how many
of the characteristic chalk grass and flora are present, then
almost all of the chalk grassland SSSIs came out in the top five
per cent of those sites and most of the other wildlife sites that
have since been designated as local wildlife sites come out somewhat
lower down that hierarchy. In my own research I have done work
on insect species in particular across a wide range of sites and
I can generally characterise SSSIs as having a much higher proportion
of nationally and internationally rare species than equivalent
county wildlife sites or sites below that designation. There may
be the odd anomaly but those may be sites which are actually designated
for geological features rather than biological ones.
Q27 Mr Boswell: You talk in your
evidence about the need for common standards and this includes
monitoring, research and analysis. If we could deal first with
the monitoring side, how much are you building that up as part
of your capacity? How much more important is it than the guidelines
initially? How much do you feel you have a handle on how the system
is evolving?
Mr Stott: We have worked with
the country agencies to develop the guidance on site monitoring.
JNCC does not undertake that monitoring; that monitoring is undertaken
by the agencies. However, we do fund some national surveys which
provide evidence which is relevant to the SSSIs.
Q28 Mr Boswell: That could be, for
example, species specific surveys.
Mr Stott: Yes. For example, we
provide funding to the British Trust for Ornithology who undertake
surveys on breeding birds. We are not directly involved in that
surveillance of the sites. In terms of our own work on surveillance
it is an increasing priority for us and although we are not in
a situation where we can put additional resources into surveillance
it is an area which we are protecting in terms of its investment
in relation to some of the other areas of work within JNCC.
Mr Eversham: I would like to make
one comment on that which cuts across this rather. Almost by historical
accident the designated sites in Britain happened just at the
time that agriculture was changing radically so that many SSSIs
represent small areas of low nutrient soils that predate agrochemicals,
pesticides and fertilizers. That gives them some really special
value that goes well beyond the species that happened to be living
there at one time. On the monitoring side I have two concerns.
Firstly, I would say that common standards monitoring is probably
about as good as it can be given the resources that go into it
but one visit or one assessment every six years tends only to
pick up fairly substantial changes. As an organisation that manages
130 nature reserves about half of them SSSIs my trust has much
more detailed monitoring on our sites and our aim is to pick up
subtle changes before they become so serious that they cannot
be corrected.
Q29 Mr Boswell: Can I just get you
to confirm that because I thought that was a surprising piece
of evidence? You are saying that in terms of monitoring the activity
by the local voluntary trusts is probably more intensive than
the coverage of national?
Mr Eversham: On the land that
we manage at nature reserves it certainly is. I have a team of
400 trained volunteers who spend their time monitoring nature
reserves. The purpose of that is to pick up subtle changes when
perhaps our management is not delivering what it should do and
in a changing climate that is increasingly the case. What worked
last year may not work next year. With those changes taking place
we want to spot the changes as soon as possible so we can do something
about them. On our own sites common standards monitoring will
pick up drastic changes by which time it is rather difficult to
put them right so that if the resources are available then more
detailed monitoring obviously allows you to get advance warning
of sites which are just slightly tipping out of condition so that
you can actually correct that earlier. To do that across the whole
network would be very, very substantially more expensive.
Mr Clark: I am not very familiar
with the common standards monitoring methodology issued by the
JNCC but the questions I would be asking if I were reading it
would be: are farmers and landowners asked to monitor the sites
and, if they are or if they are not, are their observations on
the site condition considered part of that monitoring? Monitoring
is not an end in itself; I would like to feel that that monitoring
actually does become part of the dialogue with farmers and landowners
on a regular basis so that they can feel ownership and certainly
feel, "I've done this management, this is the impact of it".
Most importantly I think it is important to put people back into
this. Natural England's evidence talks about management units
with whom we can engage; in actual fact is people who engage,
not management units. I would like to put people into the centre
of this interaction.
Q30 Mr Boswell: Can I come back to
Mr Stott on the question of research? There have been references
by all witnesses to the importance of climate change. You do say
in your evidence that you have a responsibility but a very limited
resource for carrying out research. If you take the huge challenge
of climate change would it be unfair to say that the danger might
be that before the research is carried out, let alone issues in
administrative decisions about designation, actually global warming
will have taken place ahead of the game? Or can you lever in or
influence the activities of other research bodies to do this in
time?
Mr Stott: That is exactly the
way the JNCC undertakes its work in relation to research. Yes,
we do fund some research which is largely tied into our surveillance
programmes which might be about developing more effective techniques
or doing some appraisal and analysis of the trends from that work.
More significantly in terms of addressing these areas of uncertainty,
we have a function in terms of coordinating research amongst the
country agencies and with other research funders. We provide the
secretariat to a group called the Biodiversity Research Advisory
Group which brings together most of the public funders of research,
including the Natural Environment Research Council and some of
the main research institutes to identify what are the research
priorities and the most effective way of coordinating activity
around research. We also do that in the global context as part
of a sub-group of the Global Environment Change Committee. We
work there with other government departments trying to identify
what the knowledge gaps are and what the evidence investments
should be. We are also a member of the Environmental Research
Funders Forum which is a group of all the major environmental
research funders and there we have had a role in trying to identify
specifically what the biodiversity requirements are. We also work
closely with other research funders on particular projects, whether
it is NERC funded projects or Defra funded projects or projects
funded by the European Commission. We are involved in trying to
optimise those projects.
Q31 Mr Boswell: So in terms of reporting
lines if you have a subject you are worried about that has come
to you through part of the monitoring process or representations
made are you satisfied that you can make your voice heard and
it will go up perhaps through the departmental chief scientist
networks and we will get the chief scientists and eventually result
in some change of gear in government or administration?
Mr Stott: We work very closely
with Defra and the research funders. We recognise that there are
different drivers for the research in the research councils as
opposed to within Defra. We work with NERC to try to identify
where the primary innovation and the scientific issues can be
joined with the more practical aspects of conservation. As part
of that there is now a major new initiative Living With Environmental
Change which is a programme between government and the research
councils which tries to identify more policy oriented practical
applications of research.
Q32 Mr Boswell: I should perhaps
have made clear but did not, some of the land I own was informally
in an environmentally sensitive area although we have not proceeded
to a higher level scheme; it is not actually SSSI. Can you give
us an impression as to whether nationally there is a handle on
all this in relation to the various schemes, the Defra environmental
scheme, research council activities and possibly other grant trusts
and of course the voluntary sector represented by Brian? Is somebody
steering the whole process or at least taking an interest in the
whole process and, given the exigencies of nature and time, at
least hoping to get us through some of this with a degree of rationality
and coherence?
Mr Stott: It is not really JNCC's
position to comment on that because this is a responsibility of
the devolved administration, Defra and Natural England. I believe
there is a good coordination of that within the Biodiversity Programme
within Defra. From the science perspective we are keen to work
with the major funders of science so that there is a scientific
element which addresses the effectiveness of all these different
schemes and how they interact with one another.
Mr Eversham: I would like to comment
on some of the quality science coming out of Natural England over
the last four or five years. Some of the work there actually demonstrates
what change has already taken place and is starting to give us
some practical ideas as to respond to those changes. If I could
move slightly sideways from this, one of my concerns is that the
dynamic nature of plant and animal species moving through the
landscape means that the interest features of sites are going
to change subtly but significantly over the next ten, 20 or 30
years and although I would argue that in terms of soil and physical
structure most SSSIs are going to remain of very high importance.
We may need a rather different way of evaluating that importance
in tracking its success.
Q33 Mr Boswell: By inference from
that, there is a possible change in the portfolio of SSSIs as
this situation develops.
Mr Eversham: I would guess that
the changes may be relatively small. I am thinking of our own
nature reserves, some of which we have got 50 or 60 years of good
data for. The sites are still incredibly important but they may
be important for a rather different set of butterflies or flowers
from what they were 50 years ago. The nature of the site, in terms
of soils and topography, means that they are going to remain very
important places. A lot of SSSIs fall into that category. On the
monitoring side, the one concern I will express is that there
is strong emphasis focussing inwardly on each SSSI as if it lived
in isolation when many of the problems and difficulties sites
are suffering from are actually much wider than that. I think
Defra's ecosystem approach has been really helpful here in putting
sites in, for instance, a hydrological context. There is not much
you can do to preserve an SSSI bog on a hillside if the rest of
the hillside is out of condition. Taking Andrew's point about
grazing, one of our own initiatives is actually working with graziers
to put them in touch with owners of wildlife sites and SSSIs that
need livestock. I think we are going to have to be a lot more
creative in that sort of area, so keep the five acre really important
orchid meadow in good condition when the owner of it may have
no livestock.
Q34 Dr Iddon: I am getting the impression,
rightly or wrongly, that the monitoring is not exactly well organised,
but correct me if I am wrong. There are over 4000 SSSIs in England
alone but only one per cent have been re-classified as a result
of this careful monitoring of the dynamic situation that Brian
Eversham explained a moment ago and only one site has been partially
denotified. Can I press you a little harder about the monitoring
situation? Is it well-organised? If it is not, what can be done
to make it better?
Mr Stott: I cannot really comment
on the implementation of monitoring within Natural England. Our
responsibility has been to provide some guidance and common standards
but the actual implementation of that—
Q35 Chairman: Can I just stop you
there? I do not see how you can keep saying this. You are constantly
making references that it is nothing to do with you but in reality
unless in fact you have an interface with Natural England and
one influences the other, then we are just working in separate
silos, are we not?
Mr Stott: We work constantly with
Natural England and all our advice is based on consultation with
experts within Natural England and the other country agencies.
The JNCC operates through those experts within the agencies. There
is not gap there in developing the guidance. What I am saying
is that JNCC does not have the responsibility for the implementation
of that guidance.
Q36 Dr Iddon: You must have a feel
for the monitoring. This is a critical area for SSSI as a subject;
what is your view of the way the monitoring is conducted? We accept
that you do not do it, but you must have a view on it.
Mr Stott: The JNCC's particular
interest in the monitoring is to be able to make a UK level assessment
as is required, for example, under the Habitats Directive. For
that we need to be able to collate information from each of the
agencies to make that assessment. Our last assessment was completed
in 2006; we were able to obtain reports on condition from 57 per
cent of features. We felt that was not completely adequate in
order to make that assessment. We recognise that the implementation
of common standards monitoring is variable between the country
agencies and does not necessarily provide the most comprehensive
assessment of all features. Having said that, we are reviewing
what the requirements are for UK level reporting—that is
under review within the European Commission—and it may be
it is not necessary to make an assessment within the Habitats
Directive of every single site. It may be that we need to make
an assessment of the favourable conservation status of the features
as a whole across the UK which includes a lot of the sites, but
it does not mean to say that we necessarily have to have an assessment
of each individual site. We are in the process of reviewing what
we require at the UK level in order to meet the obligations of
the UK to report on the Habitats Directive.
Q37 Dr Iddon: Mr Clark, we have received
some evidence to suggest that the turnover in staff within Natural
England is a problem and that farmers have reported that they
never see the same person twice. Have you got a view on monitoring?
Is it haphazard? Is it working? Do farmers come into you about
the monitoring of sites under their ownership?
Mr Clark: I would obviously reiterate
the points I made previously, but I do not think we can take a
view of whether the monitoring is well organised or not; that
is a case for the argument between JNCC and the conservation agencies.
We can only see it from out point of view. There is a turnover
of staff in Natural England. We did a quick round-robin within
our regions to find out what the feeling was about relationships
and some inevitable result of a rationalisation of offices in
the north-west region, for example, has meant that three of the
six offices have been closed. The relationships that built up
between farmers and landowners with those officers now is under
threat. I think it is right to say that most owners and occupiers
have a named contact. That is obviously a valuable starting point
but we need to ensure, I would hope, that the relationship is
something with a person over a long period of time so that that
relationship would come up. Monitoring is part of that relationship.
I would like to feel that the person who does the monitoring is
also the person who helps the farmer get over the problems of
actually managing that site. I do not think we can talk about
the actual adequacy of monitoring as a whole although I am a bit
surprise at Andrew Stott's comments about what appears to be a
relaxation of the monitoring regime within the European sites
which are the most internationally important sites because of
the problem of agencies' compliance with that regime. The point
I would make is that monitoring has to be a fundamental part of
the relationship between site owners and occupiers and the agency.
In a sense we farm sites just in the same way as Brian Eversham's
trust farms his sites; they are in constant contact with those
sites and have views about its condition, how it is monitored,
how it is managed and the problems they are having. You need to
have a regular dialogue and regular contact between the agency
and the owners.
Q38 Mr Cawsey: As well as this idea
that people from Natural England may change from time to time,
I speak to some local guys who have the view that it is not so
much that people change but sometimes you have the same officer
dealing with potential Habitat Directive legislation or SSSIs
and in their part of the country, because of the people they have
who are almost zealots—for want of a better phrase—it
is therefore very difficult. However, they know they have colleagues
in other parts of the country where legislation has not been so
rigorously enforced. Do you pick up on any of that, that it is
not just the legislation, it is the fact that it is not consistently
applied across the whole country?
Mr Clark: What you have picked
up here is the difference between people. The relationship between
your agency contact, your Natural England contact, your CCW contact
and the farmer is absolutely critical. In some circumstances that
is a relationship that really works; in other situations there
is tension. The fact is that each of the local people in Natural
England will have a particular interest in the site. The sites
have a range of different interests. Some of them are grassland
sites, some of them have insects, some of them are bogs or wetland
habitats. I suspect that some of the inconsistency is as a result
of different interests amongst the advisors coming along to that
site. Having said that, there are conservation objectives for
most sites but I think the National Audit Office Report picked
up that there was not complete coverage. There should be a standard
basis for that relationship and I hope that that would be the
basis for the relationship.
Q39 Mr Cawsey: Is there anywhere
to go if you genuinely thought you were being over-zealously applied
to by the agencies?
Mr Clark: They usually come to
us. If there is a problem we soon hear about it.
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