Environment, Food and Rural Affairs CommitteeFurther written evidence submitted by Plantlife

Plantlife is the organisation speaking up for the nation’s wild plants and fungi. We work hard to protect wild plants and fungi on the ground and to build understanding of the vital role they play in everyone’s lives.

In addition to our response below, Plantlife also endorses the submission by Wildlife & Countryside Link.

Q1. What actions are required across Government Departments, from local government and by civil society to deliver the White Paper’s proposals to grow a green economy and reconnect people with nature?

1. The National Ecosystem Assessment showed that plants and fungi are the fundamental building blocks of the natural environment—the very roots of a green economy. Yet flowering plants and ferns remain at the bottom of the Government’s league table for features in favourable condition on Sites of Special Scientific Interest and one in five wild flowers in Britain are threatened with extinction. An amended and updated Global Strategy for Plant Conservation (GSPC) was endorsed by Government at Nagoya (CBD COP10) in order to halt the continuing loss of plant diversity, but the White Paper made no mention of the Strategy, nor of Government’s commitment to delivering it. Recognition across Government departments of the GSPC targets and a detailed plan for their cross department delivery would significantly increase the likelihood of the White Paper succeeding.

2. As biodiversity underpins ecosystem services (and so forms the basis for a green economy), firmer commitments are required in order to protect rare and threatened wildlife. “Biodiversity 2020” must be embedded as a cross-government/department policy rather than become Defra’s responsibility. The Biodiversity Duty on local authorities must be strengthened. Although the NEWP talks of providing new tools and guidance for public bodies, there is currently no commitment to do this. Furthermore, we consider the Red Tape Challenge, which includes all 278 pieces of environmental legislation and regulations, to be a significant threat to the delivery of the White Paper. The Challenge process is neither transparent nor does it appear to be evidence-based. Government must not undo good legislation, such as the Wildlife and Countryside Act, and, indeed, should seek to use more of the powers that exist through such legislation in order to protect wildlife and the broader environment (including, for example, the power to ban the sale of invasive plant species).

3. Clearer demonstration that planning reform and the Localism Bill will not compromise the NEWP’s ambitions and commitments is needed. In its current form (whereby “local financial considerations” can be a material factor in planning decisions), the Localism Bill is not compatible with NEWP ambitions.

Q2. Will the institutional framework outlined for delivering the proposals (in particular NIAs and LNPs) be effective? Does the proposed Natural Capital Committee have sufficient powers?

4. The institutional framework for delivering the ambitions of the NEWP remains unclear and unsatisfactory, especially for biodiversity commitments (NEWP paragraph 2.9 and related Biodiversity 2020 strategy). The delivery of action to recovery our declining species and threatened habitats was previously well organised with identified national leads on species and habitats (Lead Partner organisations) responsible for developing programmes, projects and partnerships. Criticisms of the past process would be: i) a lack of integration between habitat conservation and the needs of species (it is more efficient and effective to restore/create habitats in those places that will also help recover threatened species); ii) no system to link national, regional and local biodiversity plans (local plans often failed to identify action for nationally important species in their patch); iii) poor communication channels for the needs of species through to policy and decision makers (barriers to progress and proposed solutions identified in reporting rounds were rarely addressed at Government level); and iv) inadequate action tackling the threats to the health of the wider countryside (eg atmospheric pollution, release of non-native invasive species).

5. Nature Improvement Areas (NIA) provide a good opportunity to integrate the needs of national and locally important species into habitat and landscape initiatives (this integration should be a key criteria in determining successful applications). However, to be effective the NIAs need to be supported by a national framework of wildlife information and expertise (from sources including specialist NGOs and natural history societies), which would help determine/steer how local ambitions contribute to national needs (NERC Section 41 priority species and habitats). The coordination and communication of nationally held wildlife advice to either NIAs or Local Nature Partnerships (LNP) is yet to be adequately addressed in any of the Government’s policies and strategies on the natural environment.

6. Equally it is unclear how positive results or barriers to making significant change for our most vulnerable wildlife, or natural environment more generally, are to be channelled from NIAs or LNPs as evidence on which Government agencies and departments can make policy or legislative decisions.

Q3. What further research and/or evidence is required to develop practical programmes sufficiently detailed to deliver the White Paper’s ambition to fully embed the value of nature into policy delivery?

7. The National Ecosystem Assessment demonstrates that plants and fungi deliver more value to the UK than any other wildlife groups, with land plants and fungi playing a role in underpinning all provisioning and regulating services such as water supply and climate regulation. Plants and fungi are fundamental to the supporting services (soil formation, nutrient cycling, the water cycle, primary production) too. Hence embedding the true value of plants and fungi in all decision-making is of primary importance.

8. However, in the effort to avoid double counting when valuing ecosystem services, it is the end products of benefit to human welfare which are being valued, rather than the processes which deliver those benefits (Fisher et al, 2008). Statements such as “Supporting services do not provide direct benefits to people ...” (Defra, 2011) are likely to be detrimental in the effort to fully embed the value of plants and fungi into policy delivery as it obscures the role of biodiversity from both public and government consciousness.

9. Therefore, demonstrating the links between the delivery of ecosystem services and plant and fungi diversity is critical to helping embed the value of nature into policy delivery. Research in the emerging field of biodiversity and ecosystem functioning has demonstrated that biodiversity is central to the delivery of ecosystem services. For example, Cardinale et al (2011) state:

“We now have the theoretical foundations and sufficiently large data sets that we can say with certainty that biodiversity does indeed regulate several processes that are essential to the functioning of ecosystems and that many of these functions are important for humanity.”

and Isbell et al (2011):

“Our results indicate that even more species will be needed to maintain ecosystem functioning and services than previously suggested … although species may appear functionally redundant when one function is considered under one set of environmental conditions, many species are needed to maintain multiple functions at multiple times and places in a changing world. … Furthermore, note that declines in local diversity which are far more common than global extinctions, will also decrease ecosystem functioning and services within some contexts.”

10. The NERC BESS research programme into the links between biodiversity and ecosystem service provision has the potential to help Government achieve the ambitions of the NEWP. The focus of research undertaken through the BESS programme should be on plants and fungi as these are the wildlife groups whose value is both greatest and currently least safeguarded. For example, the recent Defra report (June 2011) on Benefits of SSSIs (how the wildlife therein delivers ecosystem services) makes just two mentions of fungi in 111 pages. The report fails to establish that the presence of plant/fungi species on a SSSI does not mean there is active management to maintain/support/protect those species. If Defra are still failing to grasp the need to do more to protect plants and fungi and their diversity, then it is unlikely that other government departments are embedding the true value of nature into their planning and decision-making.

11. By avoiding double counting, major assumptions are made that the current use of ecosystem services is sustainable. Clearly this is not the case in many situations. More must be done to promote true sustainability in the decision-making processes of all local government and national government departments, and to demonstrate the long-term implications for ecosystem service delivery based on current patterns of resource use (for example, intensive farming).

12. In determining safe minimum standards and tipping points in ecosystem services, policy makers must not overlook the fact that species have intrinsic value and are, in themselves, an ecosystem service.

Q6 Does the White Paper set out an accurate assessment of the barriers to public engagement with the natural environment and make the most effective proposals for re-engagement?

13. We welcome a number of the initiatives outlined in the White Paper, including points 4.21 and 4.23 and fully support the ambition to re-engage people with the natural environment. However, we are not convinced that the White Paper sets out an accurate assessment of all the barriers to public engagement, nor that its re-engagement proposals will be effective. In some instances, for example 4.27, details about how ambitions are to be achieved is completely lacking. Similarly, the assumption that “thousands of local volunteers” can be recruited and will lead outdoor learning activities to the same standard and quality as trained and experienced professionals is unrealistic.

14. The White Paper seems to focus on safety fears/fear of litigation as the main barrier to school engagement with the natural environment. Whilst we welcome the ambition to overcome this particular obstacle, this is only one of many barriers. Cultural change is required in schools/teacher training institutions/local education authorities in order to make the natural environment an extension of the classroom.

15. Whilst we welcome the statement that “Schools should be able to teach outdoors when they wish to do so…” we do not believe that this goes far enough. Schools need to be encouraged, supported and enabled to take learning outside of the classroom.

16. The pupil premium can be used in a number of ways—it is not specifically intended to promote access to the natural environment and therefore it cannot be assumed that this will be used as part of a plan of re-engagement with the natural environment. Whilst financial support for schools is welcome—especially if it enables more children to access the natural environment—it must be recognised that it is not just children from deprived backgrounds who do not spend time in the natural environment.

17. One off interventions are important but are unlikely to lead to the re-engagement that Government seeks. One off trips to nature reserves or other sites are not enough to change people’s behaviour, outlook, prospects or attainment. More emphasis should be placed on local green spaces that are more readily accessible by communities than nature reserves or sites provided through the Natural Connections initiative. Regular contact with the natural environment builds confidence, knowledge and understanding and this is more achievable through local green spaces.


Cardinale, B, Matulich, K, Hooper, DU et al (2011). “The functional role of producer biodiversity in ecosystems”, American Journal of Botany, 98(3): 572–592.

Defra (2011). Benefits of Sites of Special Scientific Interest, Prepared by GHK Consulting Ltd, in conjunction with Dr Mike Christie of Aberystwyth University, ADAS, IEEP, Rick Minter and the Research Box.

Fisher, B, Turner, K, Zylstra, M (2008). “Ecosystem Services and Economic Theory: Integration for policy-relevant research”, Ecological Applications, 18(8): 2050–2067.

Isbell, F, Calcagno, V, Hector, A et al. (2011). “High plant diversity is needed to maintain ecosystem services”, Nature, 477: 199–202.

26 September 2011

Prepared 16th July 2012