I got an answer to my questions about implementing the new grassland SSSI designation guidelines from Natural England on 23 March. Replies are normally meant to arrive within 15 working days; I sent the first email on 31st January. Anyway, they apologised, so perhaps it won’t happen again. Many (genuine) thanks to the support advisor (the second I’ve spoken to – I think the first one left) who managed to force an answer from someone.
Basically, the reply was links to the guideline documents Natural England use for assessing SSSI designations (which to be fair to them, they can hardly say “we’re really strapped for cash; heeeeelp!” in an official reply) and also the phrase…
“These are guidelines and do not bind Natural England or the other GB statutory conservation agencies as such to notify all areas of land that may qualify or to set any timetable for notification.”
I checked again with the advisor about this phrase just to make sure that was what they meant to say as I wanted to use it in my blog, and the subsequent reply was to refer me to para 12.2 in the summary section of Part 1 of the GB SSSI guidelines (Rationale & operational approach) which sets out the status of the guidelines. http://jncc.defra.gov.uk/pdf/SSSI_GuidelinesPart1_PUBLICATION_Dec2013v2.pdf
It contains the phrase “Using this guidance, country agency staff should be able to determine and explain any selection case in the most objective manner possible.” Good! I find the best way to proceed is by being objective too; and they go on to say each case rests on expert judgement which should be “based on an assessment of the available data.”
“Available data” – what does that mean to you? The government have a dataset of unimproved grasslands on their MAGIC data site. The data-mapping concept itself is fantastic and whoever pushed for it to be created is a complete star – I really love maps and what they tell us about our culture.
However, in my area there are some ‘divergences’ between the mapped information and the present reality of unimproved grasslands. One site listed as 0.67 ha MG5 (surveyed 1991) is now covered in scrub and bramble (above pic), and part of an adjacent one (0.28 ha) is also scrub covered. One site 1.54 ha (again 1991 survey) was ploughed and reseeded in the mid-2000’s when the old farmer retired and a new one took over (you can see this if you switch the aerial photographs layer on). Another site of 1.38 ha of MG5 is listed with the comment “Uncertainty as to whether vegetation classification is MG5 or MG6 as site was “difficult to access”; when I was last there much was covered with scrub. Yet another site of 0.54 ha shows, as scrub or perhaps new woodland, on the aerial photograph.
Not shown on this MAGIC Map layer are 20 sites (all info in the public domain including NVC surveys – some paid for by Natural England – pic above is 2.24 ha of MG5 publicly owned) that would fit the current SSSI guidelines criteria including one estimated to be 100 ha; this last a particular bone of contention (I’ve never managed to get access permission to survey) and I contacted my local Natural England team about this (for context, 100 ha puts it into the top 10% of this priority plant community in terms of size in England); they said “I have also checked our mapping systems for any records of priority habitat within the [redacted by me] boundary, and the only site is a small section of open mosaic habitat at the north of the site and to the immediate west…” and yet I directed them to an independent ecologist’s report (paid for by the landowner as part of a planning application and so publicly available) that makes it clear Natural England’s data is wrong and the site is unimproved grassland.
Do you see where I am going with this? My area, the Tees Valley, is tiny (79,495 ha compared to the whole of England’s 13,027,900 hectares) and the Natural England official map layer for ‘unimproved grassland – Lowland Meadows’ is substantially inaccurate. What about really complicated and big areas like Northumberland or Durham or Yorkshire? How wrong are they? Just how accurate is the available data that the Natural England experts make their assessments on?
Going from a local viewpoint up to a national one, the 2016 Priority Habitat figures from Defra show 89,173 ha of deciduous woodland is SSSI in England and for Lowland Meadows SSSI it is 13,415 ha. A single SSSI, the North York Moors which contains the largest continuous tract of heather moorland in England, is 44,094.41 ha (I think used mainly for driven grouse shooting).
Looking at the whole of the country I’m left wondering how did our iconic English meadows and wildflower-rich grasslands, which were once one of the largest habitats in England, get to a point where they are now at least 10 times rarer than ancient woodland? Natural England’s scientific evidence says to protect all sites of 0.5 ha and over, and yet there is no timetable or even intention to act on the available data.
I think the 2016 Priority Habitat figures Defra give for Lowland Meadows are misleading and have emailed in a question about their use of the term ‘Lowland Meadows’ (they said they would reply in 15 working days) but I have used their figures anyway. You can find them here https://www.gov.uk/government/statistical-data-sets/env09-england-biodiversity-indicators on sheet 2a.
They are contradicted by the Technical Information Note 147 on MG5 grassland and the Biodiversity Action Plan figures, although since my emails with the JNCC (very helpful) over this issue they have added a note to make it clear their figures date from 2005 http://jncc.defra.gov.uk/page-5848 . Some Biodiversity Action Plan pages are archived now and, depending how you access them on the internet, are available only in Welsh.
The Woodland Trust claim about 2% of the United Kingdom (couldn’t find a figure for England only) is Ancient Woodland https://www.woodlandtrust.org.uk/about-us/ancient-woodland-restoration/ which would be 2% of 24249500 = 484,990 ha. Defra claim 36,129 ha of Lowland Meadow exists in England which would mean there was at least 13 times more Ancient Woodland than Lowland Meadow. The last BAP figures for Lowland Meadow were 7,282 ha in England which would mean 66 times more Ancient Woodland than Lowland Meadow. I think I’ve been cautious with my 10 times claim in the absence of clear figures on Ancient Woodland, or indeed Lowland Meadow.
My Local Nature Partnership ran a 3-year scrub-cutting project across 15 separately-owned LWS sites across the Tees Valley to help clear scrub from our ancient grasslands…sadly we couldn’t do all sites that needed it.
The MAGIC site is fab. and here http://www.natureonthemap.naturalengland.org.uk/MagicMap.aspx tick the habitats box and if you rootle around in there you can find the “Priority Habitat Inventory – Lowland Meadows (England)” box. SSSI sites are under the designations section. Scroll down and tick the box for aerial photos.
Last summer I did email the people who look after the MAGIC dataset and they are aware it has limitations; they have more data on paper than they can process. They sent me guidelines so that I could help them improve their dataset. At the time I was busy and as yet still have not replied. When I was younger I would have just done this in my own time; now I am far less inclined to cover-up government underfunding.