October, 2015

Our work

Our work
You might be surprised to read that our work is far broader than nature reserves and Big Garden Birdwatch. Read more about what else we do.

Martin Harper's blog

I’ve been the RSPB’s Conservation Director since May 2011. As I settle into the job, I’ll be blogging on all the big conservation topics and providing an inside view of our conservation projects. I hope you enjoy reading it and feel inspired to join in t
  • Driven grouse shooting: status quo, licensing or a ban?

    In the run up to our AGM tomorrow, there has been some debate about the RSPB’s position on driven grouse shooting.  I am not surprised - this is a high profile issue and everyone has a right to have an opinion.  However, I thought it would be useful to re-articulate our position.

    In theory, grouse moors, in conservation terms, are not inherently a bad thing. A well managed moor could offer help for curlews, golden plover and allow birds of prey to fly free from harm. Sensitive management of semi-natural vegetation, active restoration of degraded habitats, and a welcome place for walkers and birdwatchers could be hallmarks of good grouse moors. Grouse moors could be striving for the highest standards of environmental management, adapting to new science and information on things as diverse as lead shot or habitat management practices.

    But is there a driven grouse moor which does all of the above? If there is, we would love to know. As with any other land management system, there is a spectrum of intensity and not all grouse moors are the same.  Some moor owners strive for the above, but it’s clear they are in a minority.

    The current voluntary approach to meeting public expectations of what we want from our uplands, is quite obviously not working (see my recent update on the RSPB’s Walshaw complaint to the European Commission here), and the illegal killing of hen harriers and other raptors continues.  This is leading some to call for an outright ban on driven grouse shooting.  Whilst we do not yet take this stance, we can certainly see their point and the anger about ongoing persecution is shared.

    The RSPB, which has always been neutral on the ethics of shooting, has had dialogue with the grouse industry for decades, but laws protecting the nation’s birds of prey continue to be broken.  Intolerance of any predator appears to be part of the “business model” of some driven grouse shoots.

    Over the last decade we've seen a significant change in the way the industry operates, with intensification of management practices, as expectations of big grouse bags have grown. These include an increase in the frequency of heather burning, often over deep peat soils, the use of grouse medication and, in some places, the culling of mountain hares in a bid to control grouse disease; and even more intensive predator control, including the widespread illegal control of protected birds and mammals.

    Any responsible industry would take action to raise environmental standards and put pressure on those that tarnish the reputation of others.  While there are those within the moorland community calling for reform, their voice is not loud enough or being heard.   What’s worse, is that much of the grouse moor sector seem to be in denial of the impacts this intensification is having on our shared environment and wildlife. While we recognise the potentially significant benefits of grouse moor management, there is compelling and still-growing evidence that the on-the-ground reality of driven grouse shooting as currently practiced in many parts of the UK, is one where damage outweighs any benefits.

    Which, if you are concerned about these things, means the status quo is not an option.  You can either regulate through licensing, or ban it.

    We believe that the effective regulation of grouse shooting and its associated management practices, delivered through a sensible licensing regime and effective enforcement, can deliver a grouse shooting industry fit for the 21st century.  We’ve also developed and shared principles for such a scheme (here).  This would complement existing legislation such as the EU Nature Directives and domestic wildlife legislation.  Only time will tell if licensing is sufficient but it is the most logical next step, and long overdue.  And, of course, there are many questions about how a ban on ‘driven grouse shooting’ would work in practice. 

    Intensive driven grouse moor management, as currently practiced in much of the UK, is environmentally unsustainable and damaging.

    Licensing has the potential to deliver all of the benefits I mention at the top of the blog and more – notably healthy populations of upland wildlife of which protected birds of prey, such as hen harriers are a characteristic component.  It would also set out what is expected in the wider public interest from this large scale land use in the uplands and that surely has to be a good thing.

    Given the growing public profile of environmental harm associated with intensive grouse shooting, a rational industry would embrace licensing and take action to raise standards.  Governments across the UK should recognise that growing intensification is incompatible with their environmental and political commitments and as a result, they need to regulate.  

    Failure to act will simply mean calls for a ban will intensify.

    We want licensing and we want it to work.

    The status quo is not an option and we cannot allow it to persist much longer.

  • Debunking some myths about the EU Nature Directives

    This summer, 520,000 European citizens – including over 100,000 from the UK – sent a clear message to the European Commission that they place great value on the laws that protect nature (the EU Nature Directives). By using their voices for nature they have shouted loud and clear that the outcome of the current ‘Fitness Check’ of these laws should be a renewed focus on better implementation and enforcement. They, and a coalition of 100 NGOs from across the four countries of the UK, believe that making changes to these laws at a time when nature is in crisis would fundamentally undermine our collective efforts to halt and reverse the loss of biodiversity by 2020.

    The Nature Directives are important for protecting special places like the Cairngorms, for driving species recovery like Red Kite and for people such as those living in the North Kent Marshes

    But it is clear there are some who hold a different view. These people are quite difficult to identify as they seem to do their business in dark corridors across Europe and seem reluctant to speak publicly. But their main gripes are clear; they argue that the Directives are a ‘burden’ on business and a ‘barrier to growth’.

    In many debates about Europe, myths develop that are often based on anecdote rather than an objective assessment of the facts.  So, I thought I'd take the opportunity to debunk some of the Nature Directives-related myths so as to encourage others to come forwards and share their views.

    Contrary to myth, the Directives are good for nature AND business.  

    Smart businesses recognise the need to protect biodiversity, and value the clear and consistent level playing afforded  by the well-established regulatory framework provided the EU Nature Directives. This provides businesses with certainty and helps to ensure that no Member State can gain a competitive advantage over others through the adoption of lower environmental standards.  For example...

    ...Cemex – a leading supplier of cement, ready-mixed concrete and aggregates – has stated that "... sound and well implemented legislation are important in order to provide a level playing field for industry and stimulate innovation and enhanced performance. The EU Birds and Habitats Directives provide an appropriate and effective legal instrument for the conservation of biodiversity in Europe and an appropriate framework for the development of extractive activities in harmony with nature."

    ...Energy UK – the trade association for the UK energy industry – has stated that "[Our members]... are very familiar with the EU Nature Directives and consider that they are very important to nature conservation. The Nature Directives are generally achieving their conservation objectives and we do not wish them to undergo significant revision. Re-opening the Directives would introduce a degree of unnecessary uncertainty to energy project developments that would damage investor confidence at a time when it is vital to deliver new energy infrastructure...that contributes to UK and EU renewable energy targets."

    ...the European Landowners Association has stated that “One of the principal benefits of the Nature Directives is the extent to which it helps ensure a level playing field...a basic standard of environmental protection which all Member States must meet. This accords with the terms of the Single Market and its requirements for common standards and mutual recognition.”

    And both Defra  and Decc appear to agree with this view...  

    ...in its submission to ‘Fitness Check’ consultation, Defra stated that the Directives “…provide a level playing field by requiring that Member States all set a broadly similar level of ambition without compromising economic growth.” and that they “ensure that no Member State is able to gain a commercial advantage over another Member through taking lesser action”. In addition, they have “improved the development of conservation measures and raised the level of ambition”.

    ...and Decc stated that the legislation ...provides a high level of certainty for businesses...even if, in a minority of cases, the Directives do cause difficulties. It is difficult to quantify the financial benefits of the current stable legislative climate. There is a risk that if the Nature Directives were opened up for review with possible changes of an unknown nature and timescale, then this could introduce additional uncertainty which may affect investment decisions. In most cases, costs are considered proportionate to the size of the project and to the level of environmental risk.”

    Projects like Wallasea  – an innovative partnership project between the RSPB and Crossrail – also highlight the importance of the Nature Directives in driving positive and sustainable developments for people, business, and wildlife.

    Contrary to myth, the Directives do not place ‘disproportionate’ or ‘unnecessary’ burdens on business, or act as a block on development.

    The UK Government’s own review (the 2012 Habitats and Wild Birds Directives Implementation Review) found no evidence to support the “burden” claim. Instead, it found that “in the large majority of cases the implementation of the Directives is working well, allowing both development of key infrastructure and ensuring that a high level of environmental protection is maintained.” 

    In particular, the evidence suggests that...

    ...Of the approx. 27,000 land use consultations received by Natural England each year, less than 0.5% are objected to on Habitats Regulations grounds, and most of these objections are successfully dealt with at the planning stage.

    ...Defra figures for environmental regulations as a whole suggests that the costs are outweighed 3:1 by the benefits (only some of which can be estimated in monetary terms), and account for less than 2% of industry turnover on average.

    This makes it clear - the Directives do not prevent all development; they simply provide the minimum safeguard necessary to ensure that biodiversity is properly taken into account when planning decisions are taken.

    Nevertheless, the UK Government review did identify a range of practical solutions to improve implementation and reduce costs within the legislative framework provided by the Directives, including the development of clearer and more consistent guidance, more streamlined licensing processes, introduction of clear conservation objectives for protected sites and improved access to/availability of data (see also protected species below). The recommendations of the review were supported by both businesses and NGOs. Yet, as pointed out by Energy UK in their response to the ‘Fitness Check’  “many are yet to be fully implemented.”

    Contrary to myth, the Directives take a sensible and proportionate approach to protecting species like great crested newts.  

    When it comes to species like  great crested newts that are strictly protected by the Directives, there are some who believe that the Directives are placing disproportionate obligations on developers, and the solution to this is that such species should no longer be granted protection.

    While it is true that problems can sometimes arise when it comes to these ‘problem’ species, such problems need to be kept in perspective. According to the UK Governments own figures...less than 0.05% of planning permissions each year in England require a licence for European Protected Species.

    Moreover, where problems do arise, they relate not to the laws (Directives) themselves, but rather to the way in which they have been implemented. The evidence suggests that solutions that work within the existing legislative framework are available.  For example...

    ...the great crested newt has suffered substantial declines over recent decades in the UK and Europe which is why it is protected under the Habitats Directive.  The current approach to licensing development that affects this species has been criticised by some developers and landowners who feel that the cost and delays they have encountered are disproportionate (for example requiring the capture and relocation of individuals).  Fortunately, Natural England in partnership with Woking Borough Council will shortly be piloting a new approach (here) designed to speed up development and improve the conservation of great crested newts.  If successful, this will influence any future licensing regime.  

    The problems that people have encountered are nothing to do with the law, rather how we choose to implement  it.  I am pleased that creative approaches are now being explored to overcome difficulties without compromising the conservation of threatened species.

    Contrary to myth, the Directives are coherent with other EU policies... but the Common Agricultural Policy remains an issue.

    Recent reports on the State of Nature in the EU have once again highlighted that the main drivers of biodiversity loss in the EU are land use changes, and most notably agricultural intensification. At the same time, many of the habitats and species that are protected under the Directives are dependent on, or associated with, extensive farming systems and practices for their continued survival. In such cases, support is required to both (i) ensure the economic viability of the extensive farming systems on which the beneficial management depends, and (ii) addresses the specific management practices needed for the conservation of the key habitats and species.

    Unfortunately, only a small portion of EU Common Agricultural Policy supports farmers that provide a range of public goods such as an attractive countryside rich in wildlife accessible to all. It is possible to farm in harmony with nature; in the long-run, the two are inextricably linked. However, perverse subsidies and inadequate support for high-nature value farmers is hindering, rather than helping, the EU to meet its biodiversity conservation goals.

    So to conclude this rather long myth-busting blog...

    The Directives are not a burden on business or a barrier to growth. They are good for people, nature, and business. If and when problems do arise, the solutions lie in better implementation and greater investment in nature conservation.

    This is why the Aldersgate Group have called on the UK Government to “...champion smart environmental regulation in key areas of European legislation. Priorities should include...the effective implementation of the Habitats and Birds Directives.”

    The case for better implementation and greater investment in nature is supported by citizens, NGOs, and businesses. As well as deflecting attention from the much needed focus on implementation and wider action for nature, making changes to the Directives now would be undermine decades of progress in clarifying requirements and developing best practice, and would cause sustained uncertainty for developers and investors alike.

    It's time to put these myths to bed and for politicians to come out and proudly support the EU Nature Directives.

  • Plan for nature?

    Defra will start a conversation about the content of its 25 year plan for nature on 14 October.  The day before, a coalition of NGOs will launch a ten-point plan to restore nature in England (and separate plans for Northern Ireland, Scotland and Wales).  These serve as the civil society challenge to governments across the UK about their role in responding to the State of Nature report which we published in 2013. 

    I don’t want to give too much away other than to say that a key theme in our country plans will be to ensure national ambition is matched by arrangements locally to make it easy for people to protect and enhance nature.

    Before 2010, planning for nature in England happened at a regional level with spatial strategies designed to demonstrate how to reconcile competing demands for development and protection of natural assets.  A huge amount of effort was invested in mapping current and potential habitat for wetlands, heathland and other habitats while also ensuring that necessary new infrastructure went ahead without compromising the natural environment.  Those with economic interests sat down with those with social and environmental concerns and deals were done.

    That was, at least, the theory. 

    As we all know, the regional tiers of government were abolished and the coalition government placed a renewed focus on local authorities.  Since the publication of the National Planning Policy Framework (NPPF) in March 2012 (see here) a series of obligations have been imposed on local authorities to make things better for nature.  These were expressed in paragraphs 113-114 and 117-119 and include commitments to...

    ...minimising impacts on biodiversity and providing ‘net gains’ in biodiversity where possible

    ...contributing to the Government’s commitment to halt the overall decline in biodiversity

    ...planning, mapping and establishing coherent ecological networks that are more resilient to current and future pressures.  

    The NPPF has been in operation for three and half years now. Together with The Wildlife Trusts, we were keen to find out how local authorities in England are implementing its biodiversity policies through their local plans.

    We commissioned an independent consultant, The Planning and Environment Studio, to review 30 local plans adopted since the introduction of the NPPF. Yesterday, we launched the research findings.

    Image courtesy of London Wildlife Trust

    There are some positive examples of local planning authorities doing the right thing. For example, the Broadland, Norwich and South Norfolk Joint Core Strategy aims to promote a strategic approach to planning for biodiversity. It recognises the potential for new development to positively contribute to enhancing the environmental network, and it maps core biodiversity areas and buffer zones extending and linking fragmented habitats.

    Gravesham’s core strategy takes a precautionary approach to effects on European Sites and requires developers to provide or contribute to mitigation measures for the recreation needs arising from their developments.

    But many local plans miss the opportunity to set out a positive vision of what they might do for the natural environment in their area – less than a third of Core Strategies present a clear strategic approach to planning for biodiversity. This is hugely disappointing - Defra’s 25 year plan for nature will not be successful if local plans continue to underperform.

    There is lots of good practice and we want local planning authorities to learn from each other.  We know that it takes time, requires some effort to get people together and mobilise information, but the motivation must be to deliver sustainable development that benefits people and wildlife.

    Through our report we’ve proposed a set of recommendations.  We’ve highlighted what we think nature needs to ensure that local authorities deliver a coherent ecological network in every part of England.

    Nature needs...

    ...robust implementation of the NPPF

    • The NPPF is good – it just needs to be implemented!
    • DCLG and Defra, working with statutory agencies and the Planning Inspectorate, should encourage and support local planning authorities to ensure the effective implementation of the NPPF through the biodiversity policies in their local plans.

    ...a place-based, strategic vision for the protection and restoration of biodiversity, which:

    • Embeds a positive vision for the protection and restoration of biodiversity
    • Includes specific and comprehensive ecological network and biodiversity maps to inform plan-users and properly guide development decisions.
    • Sets out specific policies and actions to strengthen and/or create ecological networks
    • Recognises the hierarchy of site protection designations, from sites of international and European importance to sites of national and local importance.

    ...improved access to ecological expertise and information

    • All Local Planning Authorities should ensure they have access to good ecological expertise and up-to date information to enable them to plan and manage nature-positive development and infrastructure
    • The capacity of Local Nature Partnerships, Defra agencies and Local Environmental Record Centres should be strengthened
    • Defra should reaffirm its commitment to the continuation of LNPs and continue to work with partners to ensure their effectiveness
    • Existing conservation delivery bodies should be empowered to be independent champions for nature, with the capacity to do their job. Natural England should advise central and local government on how to achieve a net gain for nature and be able to challenge it in the instances when economic interests threaten nature.

    Nature conservation, like anything in life, needs good planning and we think that much more needs to be done at a local level to improve the current system.

    I look forward to hearing the response from central and local government to our report.  In the meantime, how do you think we can improve planning for nature?

    It would be great to hear your views.