Martin Harper's blog

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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
  • Protect the best? A week of mixed fortunes for our finest wildlife sites

    In a week when the UK Government has (see here) ruled out fracking from our finest wildlife sites, the RSPB has joined the Wildlife Trusts' campaign to protect Rampisham Down, a grassland SSSI in Dorset.  Below, my colleagues from our South West region, Tony Whitehead and Renny Henderson, provide an overview of the case.  At the end, I draw some parallels with Lodge Hill case and offer you a way to get involved.

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    This is London Calling...

    From 1939 until its closure in October 2011, the array of over thirty radio masts at Rampisham Down in Dorset broadcast the BBC World Service.  In these seventy plus years the masts transmitted daily news of a world that was changing dramatically. However, beneath the masts, within the security fences, something precious remained, protected from the changing world outside.

    Free from the wholesale farm intensification all around, the grassland around the masts remained untouched save for the attentions of a few sheep to stop it scrubbing over. And in this “unimproved” state, the grassland remained rich in plant species – species that most of us would nowadays have to make a special journey to find. Species with names redolent of an England now passed – sweet vernal grass, sheep’s fescue and hawkweeds, quaking oat grass, pignut and bedstraw.

    These sorts of grasslands are often of ancient origin, dating back up to 7000 years to the times of the first forest clearances. And they come in numerous flavours. At Rampisham botanists describe the grassland as “lowland acid grassland”, and ascribe it the code “U4” due to the very particular mix of species. U4, an unappealing title for this plant community, is, to say the least, rare with only 3-4000 ha in the UK. And Rampisham has one of the largest areas of this type in the country.

    Rampisham (pronounced “Ransom”) was sold by the BBC in 1997 to a management buyout, then sold on in 2001 to Vosper Thornycroft who subsequently were taken over by Babcock International Group. In December 2012 an application was submitted  by British Solar Renewables to construct on site a “40MW solar park following demolition of 32 of 35 existing masts and towers...”.

    The proposal involves the erection of some 119,280 photovoltaic panels mounted on steel frames fixed by short driven piles. These assemblies are to be arranged in rows along an east-west axis, with the panels facing south.  It is proposed that approximately 40.5ha of the site (56%) will be covered in this way, leaving 33ha undeveloped.

    Unauthorised building work began on site in January 2013, which the local planning authority stopped, but sadly some damage had already been caused to the site. 

    At the same time, as part of the Environmental Impact Assessment, the site was thoroughly surveyed. As a result, the national significance of the grassland, to date hidden behind security fences, was revealed. It was thus notified as a Site of Special Scientific Interest in August 2013.

    With this, Rampisham became part of our national network of precious wildlife sites, sites that are as the nature equivalent of protected buildings, the likes of Stonehenge or our great cathedrals.  Its designation meant, or at least, should have meant, that it be given special consideration when faced with a threatening development.

    The principle, as reiterated in the recently produced National Planning Policy Framework, is crystal clear:

    "proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest ... should not normally be permitted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest"

    However, on 15 January 2015, West Dorset Council’s Planning Committee voted to approve the application by British Solar Renewables to build a solar farm on Rampisham Down.

    Reacting to the news the Wildlife Trusts described the decision as both “astonishing” and “perverse”. Paul Wilkinson, Head of Living Landscapes for the Wildlife Trusts said:

    “The protection and recovery of the natural environment should be at the heart of all planning decisions.  This Council's decision goes against the statutory obligations of local authorities to protect important designated wildlife sites for future generations.  This is simply the wrong place for this development and Rampisham should be protected not destroyed.”

    Although the RSPB had not been directly involved in Rampisham to this point, this would set a terrible precedent for future development and it was immediately clear to us that this decision needed challenge. 

    As with wind farms the RSPB is in principle supportive of renewable energy developments. But as with wind farms our line is simple – they must be built in the right places, and must avoid damaging sensitive wildlife sites.

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    As I said at the beginning of this blog, the Rampisham decision had remarkable parallels with another case currently close to our hearts – the threat looming over Lodge Hill in Kent. Here too is a site that has what could be described as “urban” elements – though in this case military infrastructure rather than masts.  It is a site where the activity of its old owners had historically lent protection.  It is a site that was sold off,  a site that then had a proposed development, but on investigation linked to the application was found to be of huge wildlife interest, and thus declared a SSSI by Natural England. And it is a site where, despite it’s newfound protected status, a planning application was approved by the local council – Medway, in the case of Lodge Hill.

    Both these cases strike to the core of issues involving the planning system and the protection of our best wildlife sites. As shown above, the planning framework is clear - there should be a presumption against development on SSSIs and development should only proceed when the benefits significantly outweigh the costs.  I am unable to understand how these developments are compatible with the Government's stated ambition to pass on the natural environment in an enhanced state to the next generation when everyone knows that nature conservation starts with existing protected areas.  Indeed, the Government has a commitment, through its own biodiversity strategy, to improve the condition of our SSSIs - for 50% to be in favourable condition by 2020.

    The RSPB believes both of these cases are of national importance, because of what the decisions to date reveal about attitudes towards SSSIs. If they were to go ahead, they would also set a terrible precedent for future development.  As such they should both be called in, and their cases heard at a public inquiry before a decision made by the Secretary of State. This would be consistent with the will of Parliament that this week ruled out fracking from SSSIs.

    The RSPB will shortly be writting to DCLG requesting such a “call-in”. If you too believe that the Rampisham decision should be called in, please support the Wildlife Trusts e-action here.  I believe that we have until 6 February to make a voice heard.

    For more background information visit the Wildlife Trusts pages here or read more from Tony Whitehead on our Saving Spaces blog here.

  • The third Natural Capital Committee Report: essential reading for anyone who is or aspires to be in the Treasury

    There are two main reasons for saving nature...

    ...a moral belief that the millions of species with which we share this planet have a right to exist

    ...knowledge that nature provides essential things humans need: food, water, shelter, energy and inspiration.

    The strength of support for the former is perhaps best reflected in membership of wildlife NGOs.

    The strength of support for the latter has, up until fairly recently, been found within a fairly niche school of environmental economics.  But this has, in recent years, changed driven in part by the birth of the Natural Capital Committee.

    Yesterday, the Natural Capital Committee – which reports to the Economic Affairs Committee - published its third report.

    Now, regular readers of this blog will know that I am fan of this Committee (so much so that we seconded one of economists to work a ley component of this report), but I think that the latest report is the most impressive and important.  Previous reports outlined trends in the state of our natural assets and established a framework for analysis.  This one goes further and proposes nine recommendations for the future management of the UK’s natural capital.

    You should have a read (here) - even if only the summary.  It's very good!

    What excites me about the report is its ambition.  It goes well beyond recommending protecting what we currently have to calls for restoring what has been lost. And for doing so within a generation.  Not only does the report  demonstrate how habitat restoration will enhance our wellbeing and prosperity, it also demonstrates that ambitious plans to restore our woodlands, peatlands and coast also makes good economic sense.  I am sure that many of these messages will be reinforced in Tony Juniper's new book, What Nature Does for Britain (out next month).

    The NCC report recommends the creation of a new, ambitious 25 year plan, based on a joint government, business and civil society strategy, to restore the 'nation’s natural capital stock'.  Many of the building blocks required to embed natural environment thinking within government decision making are included in the report.  A key recommendation is to include natural capital impacts explicitly within the National Infrastructure Plan.  It also says that decisions should be subject to a ‘mitigation’ hierarchy, so that build infrastructure minimises its impacts on the natural world. 

    And, amazingly given these tough economic times, it calls for an explicit natural capital investment programme to be included in the plan.  This is essential as we know that public spending will decrease over the next parliament and that there is already a significant shortfall between ambitions for nature and available resources.

    There are seven recommendations in the resourcing section and they are worth quoting as these must be the areas for fertile policy debate (my words in italics)...

    i) Capital maintenance payments from public, not for profit and private sector asset owners ie those that look after the natural environment should be rewarded

    ii) Rents from non-renewable resources (eg oil or shale gas)

    iii) Compensation payments from developers ie those that damage the environment should pay for it

    iv) Greater use of economic instruments (eg taxes and charges on things that damage the environment like pesticides, fertilizers or peat extraction)

    v) Reforming and eliminating perverse subsidies (especially Pillar I of the Common Agriculture Policy)

    vi) Potential new and innovative sources (eg plastic bag charge, crowd funding schemes, Payment for Ecosystem Services)

    vii) Taking advantage of match funding opportunities (eg the EU Life Programme)

    My worry is that this agenda is not yet seriously being considered by the Treasury or indeed its Shadow.  At least six of the seven recommendations above will require active Treasury engagement and without it, we may be dependent on the good will of progressive business, landowners or NGOs to make progress in this agenda.

    So, I am delighted that the excellent Natural Capital Committee has decided to prepare advice for the incoming administration after the election.  Yet, I also hope that the chairman, Professor Dieter Helm, engages with the treasury teams of the each of the parties before the election.  They need to start factor natural capital resourcing into their investment programmes now.

    In terms of ambition, and in terms of the need to now be focusing our efforts on actions, I see many parallels between the Committee’s recommendations and what we are proposing in our Nature and Wellbeing Bill.  Both want to put nature at the heart of decision making, both recognise the need for bold political leadership and both are focused squarely on enhancing nature, not simply stopping the rot. 

    The NCC shows that we need bold, brave political action to start repaying the UK’s ecological debt. The Committee has set out the building blocks for businesses, communities and government to work together to restore nature. The profound thing about this is that the mechanisms of economics have illuminated a truth that has always been there – our natural world is too important to squander.

    I’d like to congratulate the Committee members, secretariat and support staff for their efforts in enhancing our collective understanding of natural capital and beginning to develop the practical means of shifting our balance from deficit to credit.

    We shall continue our positive engagement with the Committee or its successor body and will continue to do whatever it takes to put nature at the heart of government decision making.

  • The Hen Harrier Action Plan – two big unanswered questions

    The content of the Hen Harrier Action Plan has once again been subject to much commentary through social media (see here and here) .  This was triggered by news that another conservation organisation, the Hawk and Owl Trust, has agreed to run an experiment to test a scheme known as brood management.

    This is not the way to formulate policy in a highly contested area and it reinforces my view that the brood management scheme should have been put out to public consultation.  There is little trust between the grouse and raptor communities and I fail to see how deals done behind closed doors will instill confidence.

    Our position on the Action Plan and the proposed brood management scheme – see here - has not changed.

    We believe brood management could merit experimental investigation in the future, but only once hen harrier numbers have recovered to a pre-agreed level and less interventionist approaches, particularly diversionary feeding, have been widely attempted.

    We think that’s reasonable, given that it gives estates a chance to tackle impacts through diversionary feeding, and puts the beleaguered hen harrier first by giving the species a chance to recover naturally.

    Those designing or promoting the plan will have to answer a number of questions to carry public confidence (we've posed 25), but by far and away the most important ones are...

    1. What are the objectives of the trial?

    2. What is the legal basis for carry out such a trial?

    The former matters because a trial is a trial – it is designed to test a proposition and report on whether it was successful.  The latter – well, you’d want any scheme to operate within the law wouldn’t you?  But, given there is a proven and less interventionist way of reducing predation of grouse by hen harriers (ie diversionary feeding) or reducing illegal killing (ie stop illegal killing), I remain unclear as to how a trial would respect protected species legislation.

    While all of this is rumbling on, I thought it would be useful to reiterate what we should all be trying to achieve i.e. recovery of one England’s most threatened species.

    Back in 2011, the Joint Nature Conservation Committee (JNCC) published ‘A Conservation Framework for Hen Harriers in the United Kingdom’ http://jncc.defra.gov.uk/pdf/jncc441.pdf . The JNCC provides the Government with advice on nature conservation issues. The document sets out targets for what is known as favourable conservation status and identifies the constraints acting on hen harrier populations across the UK. But, what is this so-called favourable conservation status and what does it mean?

    The wording in the EU Birds Directive and Habitats Directive is the key. They say that ‘‘conservation status of a species means the sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its populations’’ and that ‘‘the conservation status will be taken as ‘favourable’ when:

    • population dynamics data on the species indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats;
    • the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future; and
    • there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.’’

    Favourable conservation status does not mean that when criteria are reached populations can be capped or managed through culling. It simply defines a ‘safety net’ to ensure populations, like that of the hen harrier in England, do not drop below dangerous threshold and when they do, that urgent action should be taken to seek recovery.

    In the current JNCC Framework, regional targets for favourable conservation status were set as follows:

    • A minimum of 1.2 young fledged per breeding attempt; • at least 44% of the apparently suitable habitat occupied; and
    • a density (number of pairs per 100 km2) threshold of 2.12 pairs per 100 km2 of suitable habitat.

    Based on an estimate of 6,636 km2 of habitat, this suggests that England should be supporting at least 61 pairs to achieve favourable conservation status. Yet, based on the total area of suitable habitat available and the best available data at the time, the authors estimated that the potential English population could be as high as 323-340 pairs.  I understand that a second version of the JNCC Framework is to be published soon.  We'll see if the numbers change.

    In 2014, there were only four successful hen harrier nests in England. So, whether you agree with JNCC’s criteria or not, we have a very long way to go to reach their estimate for favourable conservation status and even further if these birds were left to settle and breed in the areas where they should be an integral part of our countryside. Whatever methods Defra decides to back in the Hen Harrier Action Plan, we believe the test of its success will be the recovery of the hen harrier across all suitable habitat and that this should be the ultimate objective.

    The RSPB will work with everyone who wants to secure favourable conservation status and then build on that to secure full recovery across suitable habitat. That’s why we support the majority of the Defra-lead Hen Harrier Action Plan (the actions that tackle illegal persecution threat directly and promote diversionary feeding) and are stepping up our own efforts through our new EU LIFE+ funded project. You can read more about this new and exciting project and how you can get involved at http://www.rspb.org.uk/henharrierlife/.