|
UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 717-i House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE INNOVATIONS, UNIVERSITIES, SCIENCE AND SKILLS COMMITTEE
Sites of special scientific interest
Wednesday 17 June 2009 BRIAN EVERSHAM, ANDREW STOTT and ANDREW CLARK
DR HELEN PHILLIPS, MS CHRISTINA CORK and DR PETER COSTIGAN
Evidence heard in Public Questions 1 - 77
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Innovation, Universities, Science and Skills Committee on Wednesday 17 June 2009 Members present Mr Phil Willis, in the Chair Mr Tim Boswell Mr Ian Cawsey Dr Evan Harris Dr Brian Iddon Graham Stringer ________________
Examination of Witnesses Witnesses: Brian Eversham, Wildlife Trusts, Andrew Stott, Science Director, Joint Nature Conservation Committee and Andrew Clark, Head of Policy Services, National Farmer's Union, gave evidence.
Chairman: Good morning. Could I welcome our first panel of witnesses to this topical inquiry into Sites of Special Scientific Interest (SSSIs)? We welcome Andrew Stott, the Director of Science at the Joint Nature Conservation Committee; Andrew Clark, the Head of Policy Services at the National Farmers' Union; and Brian Eversham, the Conservation Director of the Bedfordshire, Cambridgeshire, Northamptonshire and Peterborough Wildlife Trusts (that is one of the biggest titles we have had). Welcome to you all. A number of my colleagues wish to declare interests so we will do that now. Mr Boswell: I ought first to declare or remind members of my ownership of land which is set out in the Register of Members' interests. This gives rise to the declaration of two other interests, one is that I am a member of the National Farmers' Union and indeed a former county officer and secondly, I had no part in the selection of Brian, but I think I should tell him I am one of his members as well. Q1 Chairman: Andrew Stott, I wonder if we could start with you. Given that SSSIs are Sites of Special Scientific Interest, what scientific evidence is used in their designation? Mr Stott: The criteria which were developed originally by the Nature Conservancy Council set out a range of aspects of the science which includes the representativeness of the site, the nationalness of the site, the size, distribution and coverage of special features. The criteria laid out for the science selection are based on the science of the distribution of the habitats and species. Q2 Chairman: There is not much science there really, is there? Mr Stott: The science is the natural history of the UK, the distribution of species and habitats. Q3 Chairman: The point I am making, Andrew, is that whatever piece of land you care to look at from Land's End to John O'Groats you will find those very same things to a greater or lesser degree that you have just described as part and parcel of the scientific view of what one of these areas is. We can go to College Green and do the same so why is that not such an area? Mr Stott: Well it is the special interest I think which is the key aspect of that. It is the features which generally you will not find anywhere else apart from in these particular areas or the most representative examples of those features that you only find in these particular places. Q4 Dr Harris: I think the question is, is this independently or objectively evaluated against some criteria that have figures or metrics of some kind or is it alternatively is that as long as they pass the threshold and there is enough lobbying that is what triggers it? Or is it a combination of the two? Mr Stott: There are guidelines which are produced which relate to the particular features and thresholds of those particular features but ultimately the legislation allows for the judgment of the conservation agencies in the designation of science. Q5 Chairman: Are you happy with the criteria as they stand now? Mr Stott: I think we recognise that the criteria are somewhat out of date. Q6 Chairman: So you would agree they need to be reviewed. Mr Stott: Yes. Quite recently the Chief Scientist Group of the Joint Nature Conservation Committee and the agencies reviewed the guidelines and decided that they were in need of update. They need updating in order to take account of legislation, changes in administration and also to take account of issues like climate change which were not really considered to be significant issues when they were originally drawn up. Q7 Chairman: Brian Eversham, do you share these concerns that the guidelines perhaps need to be changed and is there enough science in actually making the decisions? Are they objective enough? Mr Eversham: What I would say is that designations go back 50 years in many cases and were based on the best available evidence at the time. Since that time we have had considerably more survey work carried out. My take on this is that it is really a question of quantifying habitat and identifying habitat quality across the country. We have done that nationally through the SSSI system and at a county base over most of England now through the local wildlife science system according to Defra guidelines. That new survey has actually identified a lot more sites which are of similar quality to SSSIs. I did a quick analysis of my own three counties and in that patch we have 175 SSSIs; they average 79 hectares a piece, so relatively large sites. We have identified 1620 local wildlife sites but they only average 17 hectares, so given that size is one of the most important criteria for quality and for sustainability of wildlife habitats then I think it is fair to say that many of the SSSIs are sites which have been extremely well known and highly regarded for a very long time. Among the larger ones in my patch places like Woodwalton Fen was recognised in the mid 19th century as being uniquely important and one of the few fragments of intact fenland habitat. Many of the bigger SSSIs have been well known for a very long time and they are pretty well regarded no matter what group of plants or animals one happens to be studying. These sites were designated mainly on botanical criteria but they happen also to be nationally or internationally important for their invertebrate assemblage and often for their breeding birds. Q8 Chairman: Back in 1989 the guidelines for selection of biological SSSIs suggested that the sites should be called sites of Nature Conservation Interest. Is that not a better title rather than of special scientific interest? What we are talking about really is nature conservation. Mr Eversham: It certainly is about nature conservation. I think part of the difference is that back in the 1940s when the act was first drawn up ecology was very much a descriptive science so that in those days ecology was about plant and animal communities out of doors. These days most university ecology tends to be laboratory based, it tends to be rather more restrictive, so science has changed its focus, if you like. Some of us would maintain that we still need to understand ecological process at the landscape scale and that if there are shortcomings in this network they are more likely to be around climate change affecting the network and how science interacts with that around the countryside. We may come onto this in more detail when we talk about the monitoring but I think seeing sites in that landscape context is one of the big changes in the focus both of biological conservation but also of the way that agencies and government look at ecological functions and the whole concept that SSSIs have to play in ecosystem services. Q9 Mr Boswell: Following those exchanges I would like to get a better handle on what the objectives are, particularly I think for fauna rather than flora where there are local designations as it were supplementing the SSSIs. Do you sense that the majority designations as SSSIs are because of the inherent interest or rareness of the flora or fauna on the site? Or are they foci for a wider population or a basis for reestablishment? Obviously if there is only one orchid in the country I can well understand why there is a SSSI. On the other hand in certain cases you may be trying to rebuild a base. I am just trying to get a handle on what the motives are which I think, in a sense, have already been touched on. Mr Stott: Originally the purpose was to have a representation of the full range of habitats. Q10 Mr Boswell: A collection like Noah's Ark, to put it at the extremely rare end. Mr Stott: Yes, but not just the rare because it is also focussed on a representative range. As time has gone on there has been a decline in many of these features in the rest of the undesignated countryside so the sites have increased in importance in that respect and have become more of a source and a reservoir for perpetuating those species and also enabling them to recolonise or spread and disperse potentially in a changing climate. The role has changed from its original purpose to one where they actually have an additional function in relation to a more dynamic ecology. Q11 Dr Iddon: Community groups quite often apply for SSSI designations as a result of planning applications. I have a famous railway cutting in my constituency and you would be surprised what people have found in that. Of course the greater crested newt is famous among community groups. How many of these SSSI sites have actually been designated as a result of pressure like that? Mr Clark: I think in a sense you might have picked up on the pressure groups with the reference to nature conservation interest. These sites are of special interest and there are interest groups that have special interest in the features within them and the species within them. I suspect that is the reason why a number of these sites have been designated in a sense that that is a rational basis for designation of a national set of important sites and sometimes internationally important sites. I am not absolutely certain but I think Andrew in his evidence already has said that there is a recognition within JNCC that the criteria are out of date and need to be reviewed. Q12 Chairman: Would you support that? Mr Clark: I think they do. In researching the evidence that we have submitted to you I was quite taken by the fact that the guidelines for the designation of biological sites were not finalised until 1989. When you actually go and look at that the PDS typewritten script is very, very different to the type of presentation that we currently have. I certainly feel that it is a rational set of criteria; whether it is scientific in the sense that you have used the phrase with metrics and thresholds it is definitely not the case and I think that is recognised in the guidelines themselves. I quote from our evidence on page 20: "In the last analysis each case rests on matters of opinion. It is not intended that anyone would try to apply these guidelines as a rule book". So they are matters of opinion; they are guidelines; they are not thresholds. I think there might be some internationally designated sites - special protection areas for bird conservation - which are based on thresholds of population numbers. From my point of view, representing farmers groups, it is very important that there is transparency about thresholds, about the guidance and about the criteria. Whilst these might be rational they need also to be explainable so that those who own and manage these sites feel a real regard towards their science and an understanding of why they have been designated. Q13 Graham Stringer: Just before I come back to Mr Clark, can I ask Mr Stott, to try to get a handle on how SSSIs come about, there have been 55 new sites since 2001, can you give us an idea of how those sites have been decided upon? Mr Stott: No, I am sorry I cannot. You will have to ask that question to Natural England. JNCC does not have responsibility for notifying sites. Q14 Graham Stringer: You monitor them. Mr Stott: We provided the guidance on site selection which, as we said, is in some cases a bit out of date and we also provide guidance on the monitoring of those sites. We do not actually notify sites or undertake the monitoring ourselves. Q15 Graham Stringer: On a site like the Attenborough Gravel Pits where the birds that were originally designated under SSSIs have gone (according to the National Audit Office Report) but it still retains its designation, are you involved in the monitoring of that site and the recommendations as to whether it continues its SSSI status? Mr Stott: No, that is entirely Natural England's responsibility. Q16 Graham Stringer: That is clear and helpful. If I can move onto Mr Clark, I read your evidence with interest and I would like you to comment on it. I felt there was a tension in it. You have said to the Committee that there is a rational basis for the designation of these SSSIs but reading between the lines I just felt that you thought that some of that had not been reasonably designated and had led to conflicts. Is that fair? Mr Clark: Reading between the lines you are right. Having looked at the guidance I think it is quite interesting that for 40 years of designations of SSSIs there was not a set of national guidance. I guess that at that stage most of the designations were done on the basis of interest of local guidance and submitted to the Nature Conservation Council for ratification. I think because we are in a completely different countryside now and looking ahead over the next 60 to 70 years with climate change, I suspect we need to have a rather different basis for designation and I think that we should be looking - JNCC and Natural England and CCW do need to look at these sites - at whether they are still relevant, are they still necessary? For example the great crested newts, which I know is a European species of priority, are found in an awful lot of ponds. We need to have some, but do we need to have the protection that is granted to the level it is granted on every single site? There are questions. I am not saying that there needs to be action, but I think they need to be open questions and a review of that. Q17 Graham Stringer: Are you asking for a review of all the pre-1989 or 1981 ----- ? Mr Clark: There has been an incremental growth in terms of SSSIs over that period and those obviously are the ones that since then have been subject to the guidelines. I think Natural England have already started to look at some of their character areas to see how those parts of the countryside need to change or will change as a result of climate change. I think the context for conservation is different now with the fact of climate change, with the impact of the Water Framework Directive and with our knowledge of where species are and their frequency. There needs to be some further review of that. Q18 Graham Stringer: What percentage of the land managed by your members are SSSIs? Can you give us either anecdotal evidence or real evidence of the problems caused by SSSIs? Mr Clark: In terms of area probably 60 or 70 per cent but I suspect that much of the area of designated sites is actually estuary and marine sites and the wash and those sorts of things. Of the terrestrial sites I would have thought that the vast majority of sites are managed and occupied by agricultural activities. Even those owned by RSPB are often managed in some way with agricultural activities in mind. In the sense of our interest there is a real interest and there is a real need to ensure that there is a participation between environmental interest and food production at the same time. In terms of the tensions, I think there are fewer tensions now than there used to be. Certainly after the 1981 act there was quite a lot of tension around SSSIs. However, if we go looking for tensions now we still continue to find them. They are not life stopping; they are more issues of detail and irritations. Q19 Graham Stringer: Can you give us examples? Mr Clark: The sorts of things we are getting are that some of these sites are very small and they are actually difficult to manage from a land management or farming point of view. Certainly in terms of sustaining some of the livestock regimes which many of these sites require, that needs farm scale activities. You cannot just manage a site of five acres. Live stock farming is already on the economic margin with extensive grazing and some of these sites are simply too small to manage and it becomes more like a case of gardening than farming and land management. I would say that the critical point I want to bring across to the Committee is that that of relationships and communication. It is absolutely essential that those who own and manage sites understand the reasons for designations, have a good relationship with Natural England about how their sites are managed. Occasionally we find that discontinuity between the officers within Natural England causes problems for our owners and occupiers; they do not know who they should be dealing with. One officer will come along and have a particular interest in one aspect of the site; the next officer might not have the same interest in that site. Consistency of interaction between Natural England and the farming community is absolutely essentially. Finally, sometimes there is a feeling amongst my members that there is more of a box ticking mentality than a partnership. I know that Natural England is under a huge amount of pressure to get favourable condition across sites and on occasion we find that sometimes it is a case of signing the management plan and the relationship is finished, whereas we would like to see an on-going relationship and discussion about the detail of that site. We need to have that continuity across the board. As I say, I think it is a case of irritating detail rather than fundamental problems. 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. 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 towards that 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 have 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 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 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 aspects. 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 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 site. 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. Q40 Dr Iddon: Mr Eversham, would you like to comment on the monitoring situation? Mr Eversham: I would like to. The 50-odd SSSIs that my trust manages, when they were first assessed about five or six years ago, there was something like a ten per cent discrepancy between what Natural England thought of the site and what our own staff thought of the site. We very quickly explained why we took one view. It was not all in one direction; there were certain sites that we thought were out of condition that Natural England were content with and vice versa. I think we are now within about two per cent of agreement on that. I have already explained that we do rather more detailed monitoring on our sites than is possible under common standard monitoring. With certain habitats, for example ancient woodland, the rate of change in those habitats is so slow that six yearly monitoring is more than sufficient; the sites are not likely to change very rapidly. With things like low- and grasslands where two or three years' lack of grazing or over-grazing can make quite an impact, then the six years timescale is towards the upper end of what would be acceptable I would suggest. Overall my sense is that common standard monitoring is working very well in terms of picking up the very crude changes on sites. The subtle difficulties - the last five or six years typify this - I think are in extreme weather events, so we have the warmest, wettest winter, the wettest spring, the heaviest rainfall in summer. Sites look very different after a very wet spring and summer from what they did after a year's drought and if you do not know the site intimately then distinguishing between those blips and long term trends is quite an ecological challenge. I think common standards monitoring actually pins us down so that we pick up most of the important long term trends without being too deflected by the blips. If you have a heathland that is infested with heather beetle and there is a big population one year, that site will look out of condition when in fact it is part of a natural process and five years later it could be looking very good again. Mr Clark: That is why regular monitoring is so important and regular contact is so important. Our advice to Natural England is that there should be annual site visits and meetings because it is these annual fluctuations which are critical to understand how the site is changing. Q41 Chairman: Andrew, I think everybody agrees that the criteria for deciding on a SSSI need to be reviewed and you mentioned that point yourself. Do you have any plans to actually do that? Mr Stott: This is an issue which the Joint Committee is considering next week. We are putting a paper to them on our priorities in terms of work on common standards and this is one of those issues amongst quite a large number of works on common standards which they will be considering next week. Q42 Chairman: If you get agreement could you let the Committee know the outcome of that meeting? Mr Stott: Yes. Q43 Chairman: If there some common agreement it would be useful for us to put that in our report. Mr Stott: The meeting is on Monday next week. Chairman: On that note could I thank Andrew Stott, Andrew Clark and Brian Eversham very much indeed.
Examination of Witnesses Witnesses: Dr Helen Phillips and Ms Christina Cork, Natural England, and Dr Peter Costigan, Natural Environment Science Division, Department for Environment, Food and Rural Affairs, gave evidence.
Chairman: We welcome our second panel of distinguished witnesses this morning. We have Dr Peter Costigan, a Defra scientist; Dr Helen Phillips, the Chief Executive of Natural England; and Christina Cork, Principal Specialist for Protected Areas. Graham Stringer is going to begin this session. Q44 Graham Stringer: You listened to the previous evidence session; can you tell us whether you have plans to revisit the way SSSIs are designated and whether you are going to look at those SSSIs that were designated quite a long time ago to see if they should still be designated areas? Dr Phillips: I will start at the point of the guidance and, as was mentioned earlier, the guidance was finally concluded in 1989. Our view is that it is largely fit for purpose. As Andrew mentioned earlier this morning, there are certain editorial changes required to reflect the fact that we have more devolution than at the time the guidance was written, but more substantively there are some gaps. The gaps tend to be around species and habitats, usually the lower plants and animals. A good example would be fungi so the guidance for fungi was only signed off three weeks ago. The other is about thresholds and where a threshold kicks in. In terms of looking for sites that contribute to a representative sample of a particular type of habitat in the country, a couple of decades ago we might have felt that one particular level was appropriate whereas now because different environmental pressures, including climate change, a different threshold might be suitable. There is evidence that some updating of the guidance would be useful, but in the round it has served us pretty well. However, that is not to say that we are complacent about going forward and have actually set out a piece of work on a notification strategy for SSSIs. It strikes me that it might be helpful to put a bit of context around why we are only now looking at a notification strategy given that we have this responsibility across England. I think we need to reflect on the situation we inherited in Natural England coming up to three years ago now. We had little over half SSSIs in favourable or recovering condition and that figure now stands at over 88 per cent. We inherited a situation where a third of sites had no conservation objectives - or favourable condition tables as they are called - in order to make these monitoring assessments against. As of last March the situation is that every site, all of our 4116 sites have those conservation objectives. As you can imagine, that has been a pretty large piece of work. We inherited a situation where 24 per cent of sites were out of sync on their condition assessments. We did 3700 of those last year and are due to conclude 7500 of them this year which means that our condition assessment programme will be entirely up to speed by December 2010. So we have not been idle; we have been making sure that the statutory duties we have are being properly discharged, but we are conscious that there is this longer term piece of work to do and consequently have brought for discussion to our board a notification strategy. The purpose of that notification strategy - Christina will be able to tell you more - is basically three-fold. It is to ensure that we have proper representation of the diversity and range of habitats and species; it is to make sure that the most valuable of those habitats are protected and it is also to make sure that we are getting sites that are resilient in the face of climate change. Needless to say, that in itself is a big piece of work because it requires a pretty thorough analysis of some of the science that sits behind that, some of which is available but not analysed, some of which is not available and consequently that work is proceeding in tranches. Q45 Graham Stringer: I will tell you my two main concerns. The first one is that it is a one-way ratchet and I think in the National Audit Office Report the Attenborough Gravel Pits were pointed out and they are probably quite a good example where a particular bird disappeared (I cannot remember which one) but you still want to keep that site designated. Out of the 4000 sites there must be a number of those where the original features have disappeared and yet it seems that the criteria change and the sites always remain as SSSIs with the problems that there might be for farmers. What plans do you have to deal with that criticism? Dr Phillips: I will take that in two parts, we have done an initial assessment based on analysis of two regions and suggest that the potential scope for amendments or re-notifications is of the order of less than ten per cent. So this is not a whole scale exercise about needing to totally review it, but it does recognise that there may need to be some changes. Those changes will probably be principally about extending sites where we have worked out that the ecology of the site is dependent on some parameters or criteria or available land outside of it rather than a whole scale series of new sites. The previous National Audit Office in 1993 confirmed that they thought the series was more or less complete and that would continue to be our view. Q46 Graham Stringer: My only real direct experience of the designation of SSSIs is as an ex-director of Manchester Airport when, during the works for the second runway, there was an attempt to designate them as a SSSI. The airport came to see me as a Member of Parliament and when we looked at the criteria they did not seem to be very scientific. Natural England were saying that this is the best example of mere moss and there was a high density of great crested newts, neither of which was the case. It has made me suspicious that not only is the ratchet one way on previous sites but that sites are designated sometimes for not very objective purposes. I would be grateful if your comments both about that specific case and how you approach things now. Dr Phillips: I will need to ask Christina in a moment to comment on the specifics, if I may. Coming to the wider point about the suspicion, I think to be frank it would be pretty difficult for lobbying to get a site of special scientific interest through. I think perhaps what has happened in the past is that local interest or lobbying has brought a particular area to attention so there then has had to kick in perhaps earlier than would have kicked in that scientific analysis of whether or not the site is of special scientific interest. The process by which the notification occurs is extraordinarily rigorous. You have the officers on the ground who are experts in this area making judgments. Those judgments are then publicly commented on for a period of four months; anybody who has views on either side are in on-going discussions; there is every effort made to accommodate those so that we do not find ourselves making a notification in the face of objections. If we do find ourselves making notification in the face of objection it goes to a full and open meeting of our board. That meeting is held in public; the objectors or their legal representatives come and have the opportunity to state their case. I would not say that we have had judicial reviews more times than we have hot dinners, but we have certainly had our fair share of judicial reviews, all of which have shown that the process is robust. Ms Cork: I am afraid I do not personally know the specifics of the case in Manchester but we could provide a note. Q47 Graham Stringer: As I understand it, it is the only case where notification has been withdrawn and the scientific basis and judgments were pretty well demolished. That is my reading of the evidence. My suspicion was that it was both local lobbying groups who did not like the second runway, but secondly it was the direct impact of the 1992 Habitat Directive that English Nature and Natural England were expected to achieve a number of special areas of conservation via SSSIs. Is that a pressure you feel, to fit a particular number of special areas of conservation via SSSIs because of the Habitat Directive? Dr Phillips: It actually works the other way round, to be honest with you. In reality the situation is that we put forward proposals to the secretary of state for designation of special areas of conservation under the European legislation and that regime is quite separate from the SSSI regime where the notification process was actually within Natural England's gift, albeit what you have observed is that most special areas of conservation tend also to be Sites of Special Scientific Interest. The actual designation and notification processes respectively are separate. Q48 Graham Stringer: Are you under pressure from the government? Dr Phillips: To get more? No. Q49 Graham Stringer: So there is no history of saying that the European directive wants so much area or so many designations and we do not feel you have done enough in this area. Dr Phillips: No, it does not feel like that at all. If we think, for example, about the legislation that is going through on the Marine Bill where the situation in the marine environment is proposed to be different in terrestrial environment, if you think about the SSSI regime what we have got are very useful thresholds and standards set out in the notification guidance. The proposal with regard to the marine environment is that whilst measures can be put in place to make sure we an ecologically coherent network that guidance would stop short of setting out thresholds or the percentage of area that should be designated for particular features. Whilst those two regimes could potentially be different, the fact that we have that regime in the terrestrial environment, the European legislation and the SSSI legislation it does not feel like a target based system. Q50 Graham Stringer: You said your target was 88 per cent of areas that are either in a recovering position or a satisfactory position. I know those are not technically the right words, but you know what I mean. Out of that percentage of 88 or 90 per cent you are still left with only 45 per cent in the top category and the figure of 90 per cent is reached because of the inferior category of improving. Do you think that that is a satisfactory criterion or should it not be separated out so that you have to hit a higher target for SSSIs in a favourable condition? Dr Phillips: To recall the figures, as of the end of March this year the number of sites in favourable or recovering condition was 88.4 per cent; the target for the end of this year was 93 per cent and the target for 2010 is 95 per cent. As you quite rightly say, the target in the favourable category - which is the top category - is 45 per cent which is considerably lower than that combined figure. I think it is extraordinarily important that we maintain the favourable recovering category because the only difference between recovered - top notch condition and favourable recovering - is the length of time we anticipate it will take for the remedies we have put in place to deliver. We have already had an example this morning about woodland. We set the conservation objectives, we have a requirement for a particular type of management on that site and with all the resources and the best will in the world nature takes some time to recover. I think it is important that we recognise that we are actually measuring nothing more than a time lag rather than some altogether more fundamental concern about the management regime on that site. Q51 Chairman: Dr Costigan, as far as Defra is concerned, are you happy with the current guidelines for SSSIs or do you feel that they are in need of urgent review? Dr Costigan: We rely on the statutory advice from Natural England and from JNCC in this regard and we are very happy with the advice that they provide. Q52 Chairman: It does seem that everybody passes the buck to somebody else. Surely somebody at some point can say, "No, we do not think the guidance is good enough, it ought to be reviewed and we will be talking to people". Dr Costigan: There is some need for looking at some aspects of the guidance. Q53 Chairman: Does Defra think that? Dr Costigan: We take the advice from our statutory ----- Q54 Chairman: This is like from Yes Minister. Dr Costigan: We have high quality scientists to provide that advice to government. We do not try to second guess that. In fact, from what we can see from the evidence that comes forward, the assessment seems perfectly appropriate. Q55 Dr Harris: I think that is the right approach and your answer to the Chairman was reasonable, but as I understand it, it is the JNCC's advice you are talking about so it is not really a surprise to say they are happy with it and also, Dr Phillips, you said that you thought generally speaking that the guidance that underpins your work was robust and your work was robust and that is also not a surprise. I actually think I am doing a good job but I am not necessarily the best person to be the judge of that. I am just wondering why no-one has commissioned an objective, independent evaluation, not a hugely expensive piece of work but someone externally - maybe from another country who has a similar approach - to say, "Let's look at this afresh; it is fit for purpose?" Why has that not been done given these guidelines are pretty old and there have been some pretty significant changes to global ecology since then? Dr Phillips: I watched the earlier equivocation and thought I had attempted to be pretty clear and laid out four categories of criteria in respect of which the guidance could do with being updated. The first was the administrative point about reflecting the fact that the administrative arrangements have changed and devolution has kicked in. The second was to recognise the gap where there were species or habitat areas missing and the example I gave was fungi. The other example I gave you was about site selection in the face of the pressures of climate change which had not been explicitly factored in post-1989. The fourth example I gave you was the threshold criteria where those thresholds were for representativeness. That was endeavouring to be helpful about some specifics about where we feel the guidance could do with being updated. Q56 Dr Harris: It has not been updated. Dr Phillips: No, it has not been updated in regard to those four categories; we think that could do with being done. We are pleased to report that we got fungi three weeks ago and also pleased that the JNCC will be considering a wider requirement to review the guidance on Monday. Q57 Dr Harris: Very few people can boast of getting fungi three weeks ago! Dr Phillips: There was another point you made which was, are we all happy because we think we are doing a good job. I personally think it would be quite difficult to commission an independent, international review because, to be fair to JNCC, a lot of what they are doing is coordinating and facilitating the efforts of very august scientists in their field. There are not large numbers of people who understand the ecology of Britain better than the folk who are employed either by us, Scottish National Heritage and Countryside Council for Wales. Q58 Dr Harris: So all the people who might independently evaluate it have been caught in the process. That is unfortunate. Dr Phillips: It does rather raise the question of quality assurance. Q59 Dr Harris: You are quite happy that your systems are robust and certainly in terms of administration and judicial review. I want to ask you a bit about transparency. Do people write in to you giving a view on whether a site should or should not be SSSI? Do you always publish those letters and the responses? Dr Phillips: Absolutely. Q60 Dr Harris: Even if they say "private". Dr Phillips: If they say "private" my recollection is that we have to go back to them and say why it is that we would like to publish them and ask them if they would be happy for it to be published. I cannot ever remember a situation where we had any difficulty getting that agreement. Q61 Dr Harris: If Prince Charles has ever written - I understand that he does write to a number of organisations about things as a landowner because, one might say, he has an interest - that would be published. So the fact that there is no published letter from him suggests he has never written to you or your chairman. Dr Phillips: He writes to us on a number of issues. With regard to SSSIs the notification process is in the public domain. We endeavour to make sure that all of that information is in the public domain. I cannot remember any situation at all in my time where the public and the objectors have not had that entire bundle of information. Q62 Dr Harris: So there is no private correspondence on anything. Dr Phillips: Absolutely not. Q63 Dr Harris: That is refreshing. The RSPB, as you know, has been critical of the failure to undertake a systematic review of the SSSI series. Do you think that is fair criticism? It comes back to the same point really. Dr Phillips: I think it comes back to the same point about the guidance for notification. I think they are saying probably much the same as we are, that there are some areas in which this guidance could be updated. Q64 Dr Harris: I think they were talking about a systematic review of existing sites. In their evidence they state that only 23 sites were re-classified and site partially denotified. That is quite a low number and they say that a systematic review would have dealt with this earlier and quicker. I do not want you to repeat what you have said, but they are a key stakeholder. Dr Phillips: Absolutely, and I think at this point it might be helpful if we told you a little bit more about our SSSI notification strategy going forward because that will address that point. Ms Cork: Last year we looked at what was Natural England's strategy for notifications going forward and on what basis would we notify sites going forward. That actually looked at addressing the purpose of the SSSI network as a whole. There is no purpose in statute for SSSIs but it is enshrined within government policy, so there is Defra guidance on the purpose of SSSIs. As has been explained already this morning, it is around ensuring a diversity of sites and that the sites contain the most important sites. There is also reference around for now and for future generations. It is important that the SSSI series is actually sustainable and that the series itself is sustainable in the face of climate change. Building on that we are putting in place a process which will run in four stages. You can see the complementarity here with the work that has been mentioned about the guidance reviews. The first stage review is: what do we currently have SSSIs for and how are they valued? Have we got the right things in the series at the moment or are there any gaps? (I will not mention fungi again!) Then, what do we currently have for those habitats and those species within a series? We have done an initial review looking at what percentages on the basis of what we know of particular types of habitats and species we have within the series and outside the series. Before we come to a judgment on whether that feels about right or do we need to look at a higher proportion of some types of habitats due to maybe the eco-system services they provide to us, so whereas in the past we might have notified more on the basis of the intrinsic value of that site, do we want to have more in the series of certain habitats that provide us with eco-system functioning? We then need to form a view on the adequacy of the current series against those standards. Running in parallel to that we would also like to put in place a process that runs in with the condition assessment - the monitoring process - whereby we set up certain question sites that we currently have and at a very crude level ask if there is new interest there that it is not notified for? Has it lost its notification? Has it lost its interest completely? Could it do with new areas including within the boundary which will help it be resilient in the face of climate change? Is it functioning at the landscape scale? So are there other sites within the local area on which that SSSI relies that we need to look at whether those areas need to be included within the designation itself or that we could target that through maybe our other functions, so the targeting of agro-environment agreements to actually better manage some areas. That is hugely resource intensive and it is a long term piece of work, but that is what we are currently looking at. Q65 Dr Harris: There are a number of housing developments which are really needed in some areas which are held up or prevented because there is a water vole or a greater crested newt - it is usually the greater crested variety - and I am just wondering whether, if there were enough SSSIs with plenty of these beasts in them, then social housing development might not be held up or indeed necessary road infrastructure. Is that a relevant factor for you? It is always those species, it seems to me, that actually prevent people being housed or villages being by-passed. Is that part of your criteria, storing them up in certain places? Dr Phillips: I think it is really important that we think about the difference between the SSSI series and the European protected species requirements. It is laid out pretty clearly in law what it is we need to do in terms of European protected species. Where we have difficulty with developers, the difficulties with developers are hugely eased if we have early dialogue. It is difficult to think of examples where we have that conversation early on with our licensing folk about what it is that can be done to phase the development in such a way that we can find ways around for those species to be moved or for the breeding season or whatever to have passed. I think it is fair to say that it is sometimes a blocked development, it is virtually always seen as a blocked development but the art of the possible in terms of our licensing regime increases hugely if we have that discussion at the beginning of the developers' plans rather than two minutes before they want to do the work. Q66 Mr Cawsey: What do you do as an organisation in terms of priorities? I have an example, not dissimilar to what Evan was talking about, where there was potential development in the area and it was immediately discovered that there were great crested newts and water voles and both had to be dealt with. The whole development was put in jeopardy mainly because they had to be moved elsewhere and they could only be collected in a relatively short window. In fact it was missed which led to a year's delay to the cost of the developers. There was not for me a great issue about ensuring that that site was properly managed and looked after. What worried me was that this was a huge development that was very important to the area and in my own conversations, let alone other people's chats with your organisation, the view was very much, "Well, I've got this great big pile to deal with, why is yours any more important than anybody else's? We will get to it in the end." Getting to it in the end would have been too late. It was only the direct intervention of the secretary of state to Defra which led it to be yanked out and put to the top. Everything that had to be done was done, but what concerned me is that there had been no ability of the organisation to think that this actually needed to be dealt with more quickly than some of the others. Dr Phillips: I think that is a very important point and there are several things we have already done to make sure that people are more sensitive to customers' requirements, whether they are farmers and land managers or developers. Some of that has had implications. We have already about this morning that there is a perception that staff have changed on moved on and to a certain degree that would be accurate. By the end of March 2010 we will have closed half our offices in Natural England and in so doing we will have reduced our carbon footprint by 50 per cent. We not believe in having people in offices; we believe in having people in the field, talking to farmers and land managers and we think that is where the action is at. It also allows us to deliver our efficiency case for Natural England over target and a year ahead of schedule. We are due to deliver efficiencies of £16.5 million by 2010; we delivered £23 million by the end of last year. That has necessarily meant that we cannot afford any more than two or three people to do one person's job, so where a farmer might have been used to talking to one man about SSSI and another lady about an agro environment agreement, we say that these people have principally the same set of skills and they need to work efficiently when having that discussion not only so that we can do things more cost-effectively but with the fullness of time those relationships do re-cement with one conversation with somebody who really understand their business, whether that is a farm enterprise or whether it is a housing developer, but inevitably these things do take a little while to take hold. Q67 Mr Cawsey: Will you be looking at priorities as opposed to straightforward chronological issues?? Dr Phillips: Precisely. Q68 Mr Boswell: My questions are about management and they are directed to you and also to Defra. First of all, at a strategic level, given that we have SSSIs and we have nature conservation sites run by local trusts, Defra and all the other publicly supported conservation efforts, are you satisfied that the structure as a whole is being managed properly or that the machinery exists for having the kinds of conversation you have just been referring to, Dr Phillips? Dr Phillips: That is a very big question. In terms of practical, on the ground action interface with the land managers in their various guises, I think it is pretty good. In terms of the wider issues we were exploring this morning about reporting, monitoring and evidence base, I think it is getting better but I think there is clearly room for us to do more. Let me give you a couple of short examples. We are obviously keen to reduce the cost of the monitoring programme. I am not madly keen to reduce the cost of the monitoring programme while I am still 23 per cent out of sync on my programme. We need to get to December 2010; we are on target to date and frankly we would like to put this on a different footing going forward. It is every six years; is there an argument in favour of it being more targeted, more proportionate, more risk based and depending what feature you are looking at? Is there also an argument in terms of stratified sampling? If you compare and contrast the best and worst of what is happening in the different country agencies I think you will come up with a different proposition. As soon as we are up to date that is what we will do. The next question you have to ask yourself is about the shed load of other monitoring that is going on. Even within our own organisations there is monitoring going on around SSSIs and there is monitoring going on, we do it as part of a wider Defra effort around environmental stewardship. That seems a pretty obvious package of monitoring to bring together so in much the same way as we brought our advice and our agreement service to one person who has a point of contact with farmers, despite what has been said earlier we must remember the National Audit Office survey that says that 72 per cent of farmers were content and happy that they had a single point of contact and that that is working well. There is the same opportunity in the way we have done that to extend that way of working to our evidence base not only for us as an organisation but also other organisations. Q69 Mr Boswell: Dr Costigan, what is your take on it? Dr Costigan: I think it is important to bear in mind the integration of these measures. Environmental stewardship payments are often made to landowners who own or manage SSSIs but they are also made to other sites outside SSSIs. They are separate schemes in the sense of the way they are organised but they are very integrated. I do not think improving the status of SSSIs to be achieved without the existence of the environmental stewardship support to the landowners to assist that process. That is one important aspect of it. On the monitoring side of it, it is worth bearing in mind that there is now also an initiative that is led by the Environmental Research Funders Forum which Andrew Stott mentioned earlier called the Environmental Observation Framework which is bringing together all the organisations who do environmental monitoring in the UK to develop a more coherent approach to all of that different monitoring that actually goes on. Helen has already mentioned some of the aspects of monitoring that are conducted by Natural England, but of course there are also other monitoring schemes for all sorts of different aspects of the environment that it would be useful to bring together into a more coherent form. Q70 Mr Boswell: Is there scope for do-it-yourself monitoring by the landowner properly trained doing it, having a greater ownership of the activity, possibly getting some minor remuneration for his pains in doing it? Can you see this as being part of your professional effort? Dr Costigan: It is perhaps worth mentioning in that context an initiative called the Open Air Laboratory that is being led by the Natural History Museum and other organisations which is trying to encourage a much wider range of members of the public - landowners or not - to engage in measuring the environment in which we all live. Dr Phillips: A lot of farmer and land management monitoring already takes place. When an officer goes onto a site to form a judgment about the condition of the site the first thing they do is have that conversation about how things have been, was it a typical year, what is the system like? I think we need to be careful about how far we can take that. I do not want to find me or somebody else sitting in front of a similar committee with slightly different line of questioning which is not of course you are happy with what you are doing yourself and of course farmers who you are paying great big shed loads to to say it is all terrific. I think it is about how it we get that balance and that relationship. Q71 Mr Boswell: Just a quick closure on dispute resolution, are you satisfied that once designation has taken place and an agreement has been concluded, this properly balances the needs of landowners, businesses and the conservation interest and, if there is a dispute subsequently because circumstances change, that can be judiciously and properly dealt with? Dr Phillips: I think in the great majority of cases that is precisely how it works and we need to look at some of the facts. Naturally people have anxieties if there is going to be some new designation that applies to the land but at the time of that notification we explain what it is the site has been notified for, we also make sure it is very clear what the operations that require consent will be. People primarily have an anxiety about their ability from the business will be fettered because of the consent that is required to carry out those operations. In 92 per cent of cases once that application for consent is made it is granted and it is granted in a timely fashion. Q72 Mr Boswell: And properly? Dr Phillips: And properly. There is very little problem about that. The third anxiety is usually about any additional cost that they may have to bear and the fact that our incentive schemes swing in behind this in a timely fashion. The only residual anxiety is that when there are capital costs that expenditure is not always met in full, but then again that is going into the value of the land and the property and it would not be proper that it was coming in in its entirety from the public purse. Our experience, despite there always being one or two examples where issues escalate, is a happy one across the board. Q73 Dr Iddon: Going back to the voluntary activity, the National Audit Office Report of course recommends that you encourage greater voluntary activity in order to free up your conservation advisors to do the important work that they do do. Are you taking that advice forward from that NAO Report? Dr Phillips: We are indeed. I am really pleased to report that in the last 12 months the number of volunteers we have managed to attract to the cause has gone up by five per cent. That is pretty modest but it is going in the right direction. Q74 Dr Iddon: What is that in numbers? Dr Phillips: It is not a huge number; it is a pretty modest number. The bigger challenge for us though is striking the balance between giving volunteers the breadth of experience that they like to have to keep them interested and being able to target it more specifically at the delivery of some of our harder objectives. That is a piece of work we are leading not only for Natural England but across the sector to see how perhaps, if were to lend our volunteers to other parts of the environmental sector and vice versa we would be able to get a greater alignment between volunteer hours and things we actually and practically need doing without detracting from the experience for them. That is going to take a wider collaboration but it is work we have taken forward on the back of the NAO recommendations. Q75 Dr Iddon: I am a scientist and I know how important it is to record in your book every little observation, however trivial it might seem at the time, because that constitutes an important evidence base for future activity. I notice that the National Audit Office was critical of the lack of record keeping. What are you doing about that criticism? Dr Phillips: That National Audit Office recommendation actually more or less conflated two issues, one was about record keeping in our notes and the other was about our IT system called NSIS. We have many more paper notes than we have records on NSIS and there are two examples of that. The National Audit Office Report, from recollection, said that 12 out of a sample of 28 sites had been monitored at the wrong time of year. The date which our computer has on it is the date at which the overall assessment was made which might be when somebody is having a rainy day in the office as opposed to the dates on which they went previously to do the site to do the assessment. Once we did the paper check on that we were absolutely satisfied that those visits had been made at the right time, albeit it would take a huge amendment to the IT system to put in the necessary columns to reflect those dates on that. I think the bulk of that recommendation comes down to how much more investment we make in our IT system in order that more information is available. The other example of that was Andrew Stott's example where he said that 57 per cent of the features had been reported on. He is quite accurate in saying that 57 cent at a UK level of SSSI features have been reported on, but that is not the number that have been monitored. In the same way that we will have our condition assessment cycle entirely up to speed by December 2010, we will have all the features recorded on this NSIS system by the end of this financial year. Chairman: Graham, have you any last points you would like to make because this was very much your idea? Q76 Graham Stringer: I have one last quick question. Your Scottish equivalent has estimated that there is no impact of SSSIs on land values partly because they are in remote areas of Scotland. Have you carried out a similar exercise or have you any intention of carrying out a similar exercise? Dr Phillips: When we quote that figure, which we do, we are relying on their assessment. Q77 Graham Stringer: It is probably an appropriate comparator. Dr Phillips: We have not done that work; we do not currently have plans to do that work. Chairman: On that note, thank you very much indeed. Could I thank Dr Helen Phillips, the Chief Executive of Natural England, Dr Peter Costigan from Defra and Christina Cork. Thank you very much indeed for your evidence. |