Environment, Food and Rural Affairs CommitteeWritten evidence submitted by The National Federation for Biological Recording (NFBR) http://www.nfbr.org.uk

The National Federation for Biological Recording exists to champion the UK biological recording community. NFBR promotes the collection, dissemination and use of terrestrial, freshwater and marine data to meet local and strategic biodiversity information needs.

We welcome the introduction of Natural Choice2 and its commitments, but consider that it leaves much to be clarified as to how it will result in sufficient, sustainable improvement, not least in influencing wider policies and those sectors whose actions have greatest impact on ecosystem services, biodiversity conservation and local quality of life.

1. Actions Required and NEWP Delivery

1.1 Realisation of the White Paper’s proposals, including the long-delayed promotion of a green economy and the reconnection of people and nature, will depend in large part on the quality of delivery plans and their implementation, as well as the funding and other support these receive: locally and nationally. Above all, there are questions of the extent to which the objectives of the White Paper will be furthered, constrained or undermined by the policies, actions, attitudes and spending of national and local institutions, communities and individuals.

1.2 At present, there is a significant gap between NEWP objectives and their delivery. Each Government department, agency and other public body needs to sign up to the White Paper and identify the extent to which it will help meet the NEWP commitments, and the targets of its daughter plans and strategies.

1.3 For example, the Lawton Review3 (MSFN) strongly emphasises the role, which the planning system needs to play in introducing a step change to environmental management across the UK. As illustrated by the UK National Ecosystem Assessment,4 this is fundamental to sustainable development. Development can only be sustainable within environmental limits—that need to be identified and respected. However, the new draft National Planning Policy Framework appears to condense existing policy guidance,—which has failed to safeguard natural resources—without taking proper account of the NEWP’s commitments (eg Nature Improvement Areas, Local Nature Partnerships), its rationale or the UKNEA.

1.4 The draft National Planning Policy Framework needs to be revised, setting out clear, sound policy, instrumental to ensuring that development not only protects but also strengthens the natural environment and to achieving NEWP objectives.

2. Institutional Framework

2.1 The Government’s response to Making Space for Nature,5 includes the statement that Government will ensure that planning authorities are enabled to assess and identify local biodiversity assets and give them appropriate weight in local planning policies.

2.2 At present, however, it is doubtful that many LPAs have a clear, adequately detailed and up to date understanding of local biodiversity assets (or invasive alien species) to guarantee that they are given adequate weight in local plans, policies or decisions; a situation exacerbated by a lack of specialist staff.

2.3 Inconsistencies in the extent to which local authorities give priority to the natural environment, utilise biodiversity information or meet other performance benchmarks identified by the Association of Local Government Ecologists6 need to be addressed. The hugely variable extent to which the NERC Act S.40 Biodiversity Duty is implemented by public bodies highlights the need for appropriate guidance, support and prescription.

2.4 Although access to nature and biodiversity conservation have demonstrable, multiple benefits, they generally feature too low in local authority priorities, particularly in areas of deprivation, for such benefits to be realised. Currently, relevant budgets for management works and employing skilled staff are being cutback out of proportion to other public spending cuts. Lack of support will undermine efforts to foster the activities of local “Friends of” groups and other Big Society opportunities. An effective means of bridging the gaps between national goals and policies and local priorities and drivers needs to be found.

The scrutiny to be undertaken by the Minister for Government should be guided by the Natural Capital Committee, which should ecological and land/water/marine management expertise. With a solely advisory role, it is not clear how “NatCap” will be able to impose unwelcome recommendations, however sound or necessary they may be.

Whilst the institutional framework is important, the funding provided to support NEWP initiatives is inadequate, eg in comparison to MSNF figures. What funding will there be to achieve NEWP objectives beyond the identified pilot periods?

3. Research and Evidence Needs

3.1 Collection, dissemination and utilisation of high quality, up to date biodiversity information should be regarded as pre-requisite to informed policy, plan and decision making, to the identification of objectives or targets and to the monitoring of outcomes, progress, and the state of the environment, locally and nationally. Despite advances in the past twenty years, this has yet to be achieved, a significant failing that needs to be properly addressed.

3.2 With its delivery plan still awaited, the England Biodiversity Strategy 2020 provides little that is not contained within the NEWP. We welcome the importance it places on evidence, but would highlight the need for (1) an audit of biodiversity information, communication and support needs required to provide such evidence, local and national, and (2) a strategy supported by sustainable funding mechanisms to enable these needs to be met. This should enable government funding to be targeted to best effect, highlighting key gaps for environmental funders or Local Nature Funds.

3.3 Although the importance of a national ecological network is recognised, the National Biodiversity Network (NBN) needs to be better supported, eg, improving funding mechanisms for local record centres so that they are better able to foster effective local recording and evidence use, support; facilitate the efforts of national schemes and societies and local groups, putting information to more effective use.

3.4 Lack of coordination has been an important part of the failure of conservation efforts. As part of the necessary step change, there is a need to integrate (a) biological records, monitoring or other ecological/environmental data, with the planning and reporting of (b) local and national biodiversity actions and (c) site conservation management. This should be achieved by (1) sharing data between existing, parallel information systems and (2) providing or modifying tools to benefit those involved in planning, carrying out or reviewing the outcomes of such work.

3.5 This would enable conservation work and funding to be coordinated across boundaries, target recording and monitoring to best effect, identify support needs and both gain from and support site evaluations for development including appraisal of mitigation/offsetting.

3.6 As important as harnessing a-c, is the need to make this information available, in an immediately useable form, for local community use. Provision of web-based, GIS tools, that can satisfy this need and be tailored to local purposes, whilst respecting data standards, is vital.

4. Biodiversity Offsetting—Local Nature Funds

4.1 Biodiversity offsetting has been employed in the USA, but the fragmented, nature of the UK is generally very different. A variety of practices have been pursued in the UK, from mitigation confined to the development envelope to a general “biodiversity levy”, but a strategic approach has been generally lacking.

4.2 There has been no register kept of mitigation works (habitat creation/restoration) or associated monitoring, with the result that maturing sites have not been identified for species translocations. Nor have ideas about investing in proactive, “up-front” balancing which could be conducted by local authorities or their partners (improving or connecting local wildlife sites), eventually paid for via development permitted elsewhere, five, 10 or more years later on development land or windfall sites.

4.3 A rolling programme of work, involving sites for which adequate information is available, would be funded, via the development allowed each year, via green taxation nationally, locally or as a part of council tax/rates. Obligations on planning authorities and other public bodies, developers and other organisations that benefit from and/or impact on ecosystem services might also provide “local nature fund” payments.

4.4 In selecting alternative areas/options, which provide sufficient, sustainable benefit there will be need for adequate information and longer term monitoring, building on the opportunity maps identified by regional BAP partnerships. Whilst information should be stored and accessible locally, it must also be made available nationally.

4.5 Properly managed, by the Local Nature Partnership, such land-based offsetting could be employed in a variety of ways, eg, in areas within NIAs, in supporting management of the LWS network or improving the quality of connections within green grids/corridors (identified by LNPs/local BAP partnerships) and incorporated within local plan documents. LNPs will need access to adequate information (3.2).

4.6 Part of Local Nature Fund monies should be used in a flexible fashion to support activities that benefit biodiversity and local communities—including recording, training, provision of equipment and match funding for grant aid. It should not be regarded as a way of diverting local authority funds to other uses.

4.7 Different approaches will be appropriate to London and the Lake District, to woodland and the coast. A review of existing practices would provide a useful starting point for testing ideas through voluntary approaches.

5. Resources and Ecosystem Services

5.1 The Government needs to identify how the NEWP commitments, which are critical to changing the way the nation deals with the natural environment, will be funded. Since investing in ecosystem services will pay dividends overall, it is worth considering how this may be addressed through “green taxation” nationally or locally, alongside existing funding arrangements.

6. Barriers to Engagement

6.1 Despite the evidence of public support for biodiversity presented in the NEWP and the efforts devoted to the BAP process, current understanding of the importance of biodiversity in the UK remains relatively low within Europe.7 This is particularly so with ethnic communities, despite the work of groups such as the Black Environment Network.

6.2 In large part, this reflects the relative standing of the natural environment and natural history within official circles, nationally and locally, as evidenced by the proportion of GDP and local authority budgets. Whereas there are huge opportunities to be gained from the voluntary efforts focussed on aspects of the natural environment or the local community these need to be positively supported and guided rather than being viewed as a low cost replacement to local services. Although there are many examples of good practice, long-tem support (guidance, facilitation) for such efforts is often lacking, not helped by the short-term nature of most grant aid.

6.3 Although welcome, the £1.2 million intended to further development of the National Biodiversity Network is a small sum which should be carefully marshalled to maximise its benefits. This includes development of open source software to further the recording, checking, management, accessibility and usefulness of information at local to national levels for different needs, eg the sharing of data from professional surveys or academic research, targeting the efforts of local surveyors and helping local communities to make use of local biodiversity information data for different purposes.

6.4 Effective engagement should combine support for groups that are already engaged and a gradual process of awareness raising and enabling measures addressing those groups that have yet to be reached. This is where local measures, building links between communities, schools, businesses and existing groups have a real role to play.

6.5 Recording and monitoring local wildlife, undertaking management or enhancement works and identifying future needs, provided it is easy to share and access information, will not only further stimulate awareness and involvement locally but contribute to and be coordinated with regional and national objectives. We consider this critical to building links between local communities, record centres and recording group; to the appraisal, effective management and monitoring of local wildlife sites, green corridors, ecosystem services and biodiversity offset sites; as well as to recruiting and maintaining a body of dedicated and skilled recorders across the country.

26 September 2011

1 http://www.nfbr.org.uk

2 HM Government (2011) The Natural Choice—securing the value of nature. TSO.

3 Lawton, J H, Brotherton, P N M, et al (2010). Making Space for Nature: a review of England’s wildlife sites and ecological network. Report to Defra.

4 UK National Ecosystem Assessment (2011). The UK National Ecosystem Assessment: Synthesis of the Key Findings. UNEP-WCMC, Cambridge.

5 Defra (2011). Government response to Making Space for Nature review.

6 ALGE (2005) Increasing the Momentum.

7 Attitudes of Europeans towards the issue of biodiversity—Summary Wave 2. 2010. Directorate General Environment. http://ec.europa.eu/public_opinion/flash/fl_290_en.pdf

Prepared 16th July 2012