No specific guidance

Yesterday Defra replied to a complaint I made. They thanked me for my “emails of 5 January, 30 June and 1 August” and apologised for the long delay in replying which was due to them receiving too many emails from people “Defra is currently dealing with high volumes of correspondence.” *deadpan face emoji*.

Common Bird’s-foot-trefoil seed heads, ripe and ripened – the twisting like a brandy snap happens as the pod dries out and explosively releases the seeds

Anyway, if you have studied conservation at all and conservation of plants in particular, you will be aware that the fundamental purpose of our conservation activities is to conserve as much within-species genetic diversity as we can. We do this because we can’t know which particular genetic traits in (say) wildflowers are important; you might be delighted to see a Common Bird’s-foot-trefoil smothered in flowers and be less inclined to preserve one that only had a few flowers, but if the many flowered one died in a summer drought whilst the few-flowered one developed deeper roots to be more drought tolerant then you could have made the wrong decision.

Except it’s more complicated than that because Common Blue caterpillars rely mainly on the foliage of Common Bird’s-foot-trefoil and some plants may be more edible than others and there is nothing visual for a person to choose between them. Actually, it’s more complicated than that because there is bound to be a variation in each Common Bird’s-foot-trefoil plant’s ability to fix nitrogen which relates to their ability to form a root symbiosis with bacteria from the genus Rhizobium or Bradyrhizobium and that in turn may affect the fungal diversity of the soil (if the nitrogen compounds leak out into the soil too much) and all the microbes that live there too.

Your best option is to save as much variation as possible and spread your bets against future climate change in general and in specific at the site in which your plants are growing.

And given that is just a few sentences on one plant species it’s easy to see that it’s complicated. It follows that if you were wanting to advise conservation practitioners on what best to do you would need a team to study all the science, spot gaps where more science needs commissioning to aid understanding, commission the science, read the results, and then produce expert guidance.

A very upright and vigorous Common Bird’s-foot-trefoil used in landscaping for a flood relief scheme by the Environment Agency and unlike any of the Common Bird’s-foot-trefoil found in Heritage Habitats locally (photo in May 2022)

“We can confirm that we do not hold specific guidance on conserving within-species genetic diversity on GOV.UK.”

said the reply from Defra. As far as I know that is the first official acknowledgement that there is no specific guidance on how to best conserve England’s genetic diversity on the government’s main information channel. Even though I knew, because I’d checked, it’s still shocking to me that for the most fundamental thing in conservation there is no guidance from government. There are masses of words on conservation and strategies and all sorts of stuff like that – oodles of it – but it seems like the whole of the conservation profession has carefully ignored the central purpose of what we are trying to do and for the life of me I can’t work out why.

When I wrote my complaint I thought that perhaps it was Defra’s role to produce guidance for other public bodies under the Biodiversity Duty because the Law states “[F2The] public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity.” and one of Defra’s functions is to provide guidance for public bodies, right? I’m asking because I’m currently trying to find an existing law that I can use as a lever to help protect England’s Priority and Heritage habitats (mainly Ancient Grassland as that’s what I am interested in) because it is legal to destroy them and the genetic variation they contain, unless they have SSSI designation or you plough the soil of a site greater than 2 ha in size.  

It’s possible I am wrong about Defra’s role because they replied

“With regards to the duty to have regard to conserving biodiversity, which is provided for in Section 40 of the Natural Environment and Rural Communities Act 2006, there is no requirement for Defra to provide guidance to public authorities on conserving within-species genetic diversity.”

That answer made me think of the political satire ‘Yes Minister’ which I loved watching on tv as a child and I wonder if Defra’s answer was technically correct as there is no specific mention of the need to provide guidance written in the Law. Maybe Defra has no requirement in law to produce any guidance at all – I don’t know. It looks complicated to me.

Colour variation in naturally occurring Wild Angelica flowers

In this case I will be writing to ask the newly formed Office for Environmental Protection to investigate and let’s hope they are able to do as thorough a job as the Office for Statistics Regulation were able to do with Defra’s decision to publish two completely different numbers for the extent of the same habitat, Lowland Meadow (see https://theintermingledpot.wordpress.com/2020/01/10/mis-reporting-of-the-data-in-england-biodiversity-indicators-priority-habitats-2018/ ).

And as an added plea, if you work in conservation then do ask your boss if they have any up-to-date information on how best you can conserve within-species genetic diversity in your patch. I don’t think anyone has done such a scientific review for England as yet so they won’t be able to give you any information, but it is important that whoever makes the decisions or decides the strategy in your organisation knows what information they are lacking. They might even do something about it.

As ever, a thank you to whoever answers my emails at Defra – genuinely much appreciated. I’m very glad to live in a democracy where we can actively question how the government operates – though I’d be happier if everyone voted for a political party that cared a bit more about conservation, and people for that matter.

Email exchange as follows: –

5/1/2022

Hello

Do you have any guidance available on the importance of conserving within-species genetic variation as part of complying with the law, in particular the Natural Environment and Rural Communities Act 2006, Section 40?

I’m currently investigating how public authorities undertake their biodiversity duty. To conserve a species we must conserve the within-species genetic variation of that species; the law informs public authorities that they have a “duty to conserve biodiversity” and so logically they must conserve within-species genetic diversity of our native species and therefore I would expect the government to supply guidance or advice on how to do this.

I have been unable to find any guidance on your website page of guidance for the biodiversity duty https://www.gov.uk/guidance/biodiversity-duty-public-authority-duty-to-have-regard-to-conserving-biodiversity and I know from your answer to a previous question EIR2020/22996 that Defra did not carry out an appropriate assessment on whether any within-species genetic diversity would be lost before starting the Badger cull.

As part of my book on England’s Ancient Grasslands I am looking into how well our native grassland plants are being conserved by public authorities but also covering broader issues of conservation where appropriate to provide context.

Many thanks

Martin Allen

No answer from Defra

30/6/2022

Hello

The Office for Environmental Protection (OEP) has said I need to follow the Defra complaints procedure with regard to my conservation query and I think it relates to polices/legal issues https://www.gov.uk/government/organisations/department-for-environment-food-rural-affairs/about/complaints-procedure#policies-or-legal-issues  which says I should address my complaint to the Head of the relevant policy division. I rang the Defra helpline to find out who that might be and was given this email. Please forward my email to the relevant person with Defra to answer.

I am writing to point out that Defra is not fulfilling the requirements of https://www.legislation.gov.uk/ukpga/2006/16/section/40  with regard to providing guidance to public bodies on conserving within-species genetic diversity of native plants.

Conservation of native plants means we need to protect/conserve within-species genetic diversity but Defra offers no information on how to do this to public bodies  (Natural England have no native plant conservation strategy to protect within-species genetic diversity: Access to Information Request – Request no 5205 ), and so as a consequence public bodies have no access to scientific information on whether use of non-local wildflower seed purchased from a seed merchant for habitat creation will be deleterious to the local genetic diversity of those species and as such no way of assessing whether they are complying with the law.

Defra are aware of the requirement to conserve within-species genetic diversity of native plants as the document Defra use to define biodiversity (“Defra defines ’conserving biodiversity’ as set down in chapter 1 of the 1994 Command Paper ‘Biodiversity: The UK Action Plan’ (Cm 2428): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/272038/2428.pdf ” EIR2022/00670) makes its importance very clear. The webpage https://www.gov.uk/guidance/biodiversity-duty-public-authority-duty-to-have-regard-to-conserving-biodiversity#:~:text=As%20a%20public%20authority%20in,enhancing%20a%20population%20or%20habitat gives no indication that within-species genetic diversity is important and I can find no guidance from Defra on the matter.

Because Defra is not providing appropriate guidance (the exercise of [its] functions) to the rest of the public authorities, then Defra is not carrying out its duties with respect to the Law.

If you think that is not the case please outline why, so I can then take that information to the OEP to investigate if that proves necessary.

If you need more information from me to answer my complaint then do let me know.

Many thanks

Martin Allen

I’m currently writing a book on Ancient Grassland in England (as we have no definition for it in literature or protection for in law; nor do we have protection in law for national priority habitats that are not designated SSSI) and as part of that I am looking at how to use existing law to protect them. If public authorities are genuinely bound to the law to “conserve biodiversity” (i.e. within-species genetic diversity) then the seeds from ancient grasslands automatically become a source for creating new grasslands – conserving the original sites and local within-species genetic diversity.

My blogs on the subject are here  https://theintermingledpot.wordpress.com/local-flora/

No answer from Defra after a month (20 working days) “We aim to respond to queries within 20 working days, however due to the current volumes of correspondence we are receiving there could be a significant delay.” Defra

1/8/2022

Hello

I’m just following up my complaint as I haven’t received a reply yet. If there is a problem with replying can you please let me know

Many thanks

Martin

Defra reply 3/8/2022

Dear Martin Allen,

Thank you for your emails of 5 January, 30 June and 1 August about the availability of guidance on the importance of conserving within-species genetic variation to help public authorities fulfil their own duty. I apologise for the long delay in responding. Defra is currently dealing with high volumes of correspondence.

We can confirm that we do not hold specific guidance on conserving within-species genetic diversity on GOV.UK.

With regards to the duty to have regard to conserving biodiversity, which is provided for in Section 40 of the Natural Environment and Rural Communities Act 2006, there is no requirement for Defra to provide guidance to public authorities on conserving withinspecies genetic diversity.

Yours sincerely,

Ministerial Contact Unit

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Middlesbrough’s Avenue of Trees

We first see Middlesbrough’s Avenue of Trees in the work of Kip and Knyff published in 1707 though possibly drawn in the late 1690s. It’s a picture of extraordinary modern wealth stamped right across the landscape; a newly-built brick manor house facing south with formal gardens and fish ponds in front of it – and stretching out towards the viewer at the front of the engraving a double row of trees, pacing across the grassland one by one.

Its inclusion in the book ‘Britannia Illustrata’ depicting an epic 80 best-of-the-best gardens in England of the time is testament to the newly acquired wealth of the owners, Sir William Hustler (knight) and his wife Anne, not least because it cost £10 to be included.

It was a new age of change. The landscape around the Hall had been huge open arable fields and wildflower rich pastures dotted with scrub open to all to walk across was now being Enclosed – divided by hedges into individual private farms in pursuit of a richer, more comfortable life; for some but not all. There is, in one of the rooms in the Hall, a painting of the Hustlers with Dame Anne carrying a then fashionable and rare guinea pig and the ceilings of the Hall are noted for their skilful decorative plasterwork. It is the only Grade 1 listed building in Middlesbrough, although technically it has been longer in the village of Acklam than it has the new upstart town of Middlesbrough, in which it is now a suburb.

We next see the Avenue of Trees in the vast 4 m high oil painting of the manor of Acklam dated 1716 which can be found in the Dorman Museum  http://www.dormanmuseum.co.uk/galleries/the-lordship-of-acklam-plan/ – the gardens have changed slightly, or rather aged as gardens do, and there is less money now to look after them so they are less elaborate but the Avenue remains, striding out as two lines of equally spaced single trees across the arable fields until it meets Low Lane, then the main route into the area for anyone visiting.

Puzzlingly, when we next see the area on the OS maps from 1853 the Avenue is halved, stopped at what is now Acklam Road making us wonder if it ever did reach right down to Low Lane. Was that map in oil-paint a big fib?

Maps courtesy of National Library of Scotland https://maps.nls.uk/ which is such an amazing resource to the researcher

If we look closely and know what to look for, we can see there is evidence in the map to prove it did reach Low Lane. That short hedgerow at a different angle to the rest of the hedgerows making a tiny field is only there because Lord Hustler acquired the land so the Avenue could reach Low Lane. You can see how it lines up with the end of the remaining trees of the Avenue.

No point being rich if visitors don’t know exactly how rich, and that initial glimpse of the Avenue was like putting up a signpost saying my land starts here and don’t you forget it.

And the Avenue of Trees is still there today – much beloved of the many local people who walk their dogs. In the recent past it was usually found heaving with a mass of children migrating randomly towards one of the four secondary schools in the immediate area, only that was a time when we walked to school and before the schools were surround by high security fences.

None of the trees left now are original, nor are any placed in exactly the same places they were in 1680 after the Hall was built: The Avenue of Trees that it was originally is now no longer there and hasn’t been for more than a century, only the idea of domination over the landscape remains as intended, planted, felled and replanted, and that is reduced by more than half.

The original bits – still there if you know what to look for – are a wildflower, pignut, that would have grown exactly there when the area was a medieval grazing moor, and bracken, a creeping fern which would also have lived in the area for far longer than the any of the trees or even the idea of an avenue. Any gorse (whin) or broom around will be direct descendants of those once found in Broom (yes actual field name, now a 1940s housing estate) or nearby Whinney Banks (ditto but currently being rebuilt) and you won’t be surprised to know that none of these local plants are protected, celebrated or even noticed for what they are.

The leaves of pignut start to grow in the late autumn and you can find them over the winter if you look carefully

The green fronds of bracken die back and turn russet-brown in the autumn bleaching over the winter

The Avenue of Trees is now part of an official conservation area but protected alongside the trees is an idea; that we should value the changes a wealthy landowner made to the landscape, marking out his territory at a time when common land was divided up amongst the wealthy into private hedged fields and so preventing ordinary people from roaming freely as they once could across an open medieval landscape rich in wildflowers. And the trees we see today that bring that idea to life aren’t even authentic, not even the progeny of the originals but, on the whole, different species entirely.  The pignut is genuine, the bracken, the gorse and the broom are too, but everyone is aspirational now and trees and more trees are still seen as better and more important than the wildflowers that have always been present through the ages, a direct link to the landscape of Acklam’s medieval past.

I mean, we can actually value both but we don’t, do we?

NOTES

The changes to Acklam Hall, the current one plus its medieval timber-framed predecessor, and the surrounding landscape have mirrored the ups and downs of landowner finances over the last 1000 years and, as such, that of England: It is currently a restaurant, with rooms in the attic rented to small businesses, and surrounded by a newly-built housing estate, though the view from the first-floor windows remains of an Avenue of Trees, just not the original Avenue of Trees.

Losing Lowland Meadows

On the governments MAGIC website https://magic.defra.gov.uk/MagicMap.aspx which “provides authoritative geographic information about the natural environment from across government.” the Priority Habitat Inventory – Lowland Meadows (England) dataset shows 15 sites in the Lower Tees Valley – a total of 25.2 ha set within approx. 80,000 hectares of land. For comparison, we have approx. 1300 ha of ancient woodland (my only ref. for this is an unpublished report of an ancient woodland survey carried out in 2010/12 but at least it gives you an idea of the difference in relative extent of the two habitats) of which more than half is ancient semi-natural woodland.

Of those Lowland Meadow sites I an sure that seven (6.3 ha) are no longer MG5 because I have either personally visited them as part of my Local Sites surveys to check or because I can see that they are covered in scrub via the aerial photograph on the MAGIC site. One site (2 ha) is about to be surrounded by a new housing estate and the ecology report states it is no longer MG5 due to horse grazing and nutrient enrichment  (http://edrms.hartlepool.gov.uk/NorthgateIM.WebSearch/(S(jtinv555ikd3cnfs0ikvkm55))/Results.aspx?grdResultsP=2)  

A site ploughed in 2007/8 (photo) but still (16/2/2021) mapped as Lowland Meadow on the MAGIC website

Older aerial photos (shown above) on MAGIC even showed where one site had been ploughed – a new tenant farmer presumably had not read the details of surveys of their land or didn’t care. On all seven sites now without MG5, the primary dataset that MAGIC used was pre-2000, most being the 1991 Lowland Grassland Inventory survey.

Of the remaining mapped land area, one site is now ungrazed and whilst it has a few interesting species present, the whole could not be called MG5 (2.1 ha) and one is the mown sides of Lockwood Reservoir built in 1872 (1.9 ha) which I have not surveyed. The others are still MG5 or close to that designation.

Three SSSIs (total 7.6 ha) are mapped within the dataset and two I think are still okay but I’ve not personally checked and neither have Natural England, but one had a pond built on it with trees planted around and then five years of fertiliser application, though Natural England immediately investigated in 2018 when I drew their attention to it – I’d spotted the tractor tramlines on an aerial photo and thought they were indicative of fertiliser application. According to the MAGIC data Defra knew of the pond in 2009 as they measure it separately (as MG5?) but presumably the pond was missed when Natural England reported their visit in 2011? Or maybe it was interesting grassland destroyed by the pond – who knows? Anyway, some of the MG5c still remains apparently.

The Lower Tees Valley Lowland Meadows dataset on MAGIC is not the full extent of Lowland Meadow habitat (MG5 & MG4) in the area, but it is the only dataset that is checked by developers and local authorities when deciding to develop land. So not only does it fail in being accurate, it fails us all in conservation by giving the appearance of accuracy. If the 50% accuracy rate in the Tees Valley is the same across England then that would be so depressingly awful it is difficult to type, and yet this dataset is used in most government statistics and reporting by Natural England and Defra.

What concerns me even more are the sites that are MG5 but not shown on the dataset, because what isn’t known about officially will get no protection or appropriate management.

When the Parliamentary Under Secretary of State Rebecca Pow MP tweeted that restoring Nature was a “top priority” on 9^th November 2020 https://twitter.com/pow_rebecca/status/1325794905638252552?s=20 I asked Defra “Please can you inform me how much the government are investing in restoring nature?” Defra replied (EIR2020/29965) and after a list of links to information they publish reporting about Nature “…we can inform you that since 2018/19, government has introduced or announced significant new funding for nature. We have not yet collated and analysed this data, but it includes, for example: …” and they give examples which don’t involve very much money and go on to say they “…are currently reviewing the available data on biodiversity expenditure to ensure so that we can give a fuller picture in future updates.” that report due March 2021. And they also mention net gain “…delivering annualised natural capital benefits of around £1.4 billion” estimated, obv.. It was a surprisingly comprehensive answer because in my reasons for me asking the question (which I give to add context) I explained

“I saw that the government has announced how much they are spending on building roads (£27 billion https://www.gov.uk/government/news/27billion-roads-investment-to-support-64000-jobs ) so I thought if I could compare what was being spent on Nature with road building it would help show the comparative importance of the two actions to the current government. As Conservatives believe very much in value for money and a business-like approach I thought I would be able to find a costed approach to restoring Nature in the same way that there is one for road building, unfortunately I haven’t been able to find one but I may not be using the right search words or perhaps it hasn’t been published.”

Not having a costed timetable for achieving clear conservation goals is what I would call incompetent governance. If we don’t know where or how much of our National Priority Habitat – Lowland Meadows can be found then we can’t monitor or manage it successfully, and if we don’t have clear conservation goals for what should be one of our most common grassland vegetation types (currently far rarer than ancient woodland) then how can we successfully restore Nature? 

UPDATE 18 February 2021

I should really have read through more thoroughly the links in the Defra reply mentioned above. In 2018/19 £473 million of UK public sector funding was allocated to biodiversity in the UK, that spending had fallen in the last 5 years by a third and was 0.022% of GDP. Section E2 UK Biodiversity indicators – GOV.UK (www.gov.uk) I couldn’t find a separate figure for spending on England. It will be interesting to see what the March 2021 report says.

We are failing at plant conservation in England

Summary: Conservation means conserving within-species genetic variation as well as the species themselves; there is currently no national strategy for English native plants to do that. In the blog I point to examples of regional genetic variation/ecotypes and suggest local seed would be the most cost-effective biodiversity-rich climate-change-resilient option to use for the basis of creating new grasslands within the government’s 25 Year Environment Plan, and it would also conserve England’s native plants.

If we are to conserve earth’s biodiversity we must try to conserve both the species and as much of the genetic variation within each species as we can. Gene diversity is something that gets attention in conservation when dealing with a very small population of animals* or birds where the concern is the health problems associated with inbreeding, but rarely considered when we think of common plants whose ecotypes may be found across many different habitats or exhibit geographic variation. Given the likelihood of additional challenges to conservation from climate change, we have need of the broadest range of genetic variation possible as a starting point from which to expand the UK’s semi-natural habitats to maximise our chances of success in creating new robust ecosystems.

I asked if Natural England had a strategy for conservation of genetic diversity within plant species and they do not (RFI 5205), with the exception of crop wild relatives which is a specific biodiversity indicator in “Biodiversity 2020: A strategy for England’s wildlife and ecosystem services” and is currently under review. To be fair, I had already guessed Natural England didn’t have one following a previous question asking if there was any plan to replicate the gene-bank within each SSSI designated for its grassland (TO2018/27538), such that if one was irreparably damaged we had a genetic copy. I asked because I noticed one of the three grassland SSSIs in my area had been damaged and I was concerned our only inland population of dyer’s greenweed** had been destroyed (the SSSI had been damaged but the population was still there – the local team checked & reported back to me). There is no plan to make genetic copies of grassland SSSIs or indeed any plan for creating such a plan that I am aware of, which is odd to say the least because Natural England strategies all point to SSSIs being the cornerstone from which our native biodiversity will spread in the future. With plants, most seed will only spread from SSSIs if you physically pick up the seeds and move them to a new site (this chalk grassland paper suggests >100 years for seeds to move and grow naturally elsewhere https://onlinelibrary.wiley.com/doi/abs/10.1111/avsc.12076 but it’s a bit more complicated than that, as you can imagine); if no-one is planning to move those seeds then the 25 Year Environment Plan as a vehicle for native plant conservation has failed before it even starts because it doesn’t address that within-species genetic variation. And that’s just the SSSIs; the local species-rich ancient grassland sites (Local Wildlife Sites, Sites of Nature Conservation Interest) are all under the umbrella of planning rather than conservation and have been steadily damaged (see this from the Wildlife Trusts, shocking in 2014 and it’s probably worse now  https://www.wildlifetrusts.org/news/save-our-vanishing-grasslands-petition-goes-top ) and as I have found in my area there is no way of stopping damage from happening or punishment to the landowner afterwards. The local sites aren’t even on the radar for seed use, let alone part of a national strategy.

You might wonder if there is evidence to show regional genetic variation within plant species – well there is – colour variation in the keel of common bird’s-foot-trefoil flowers is a satisfyingly fascinating story  https://botsocscot.wordpress.com/2020/06/22/plant-variation-and-citizen-science/ , this paper about the effect of genetic diversity on vegetation influence of yellow rattle https://besjournals.onlinelibrary.wiley.com/doi/full/10.1111/1365-2745.13050  , and then this splendid and disturbing review of the subject from 2004 that seems to have got lost down the back of Natural England’s sofa “A review of the potential effects of seed sowing for habitat re-creation on the conservation of intraspecific biodiversity. Defra Contract BD1447.” – search and it pops up as a Word .doc to download. This study from Germany on genetic variation within grassland plants and the need for seed collection zones https://besjournals.onlinelibrary.wiley.com/doi/10.1111/1365-2664.12636  And for those old enough to remember – a thank you to the Flora Locale website which influenced me greatly many years ago; their documents are now held here https://cieem.net/i-am/resources-hub/  .

At the scale of ecotypes, in the past botanists were familiar with the early-flowering common knapweed of floodplain meadows as noted in Marrsden-Jones and Turrill’s 1954 book on British Knapweeds, though I doubt many people reading this will have consciously seen and noted it. There is a similar version of devil’s-bit scabious and I have observed the same in great burnet – the floodplain ecotype flowering and seeding earlier than those plants remaining in the tiny relics of the once vast medieval grazing moors. There is the devil’s-bit scabious ecotype that grows in acidic dry soils and another on marshy clay ones. Sell and Murrell in their introduction to the first published volume of their British Flora https://bsbi.org/variation-in-sell-murrells-flora point out bulbous buttercup has variants that grow on chalks, the sands and the clays. Micro-species are better known now, but those within the Goldilocks buttercup group haven’t yet been fully described and some microspecies grow in grassland not woodland and could well be endemic – mentioned second in this blog by Brian Eversham https://www.wildlifebcn.org/blog/wildlife-trust-bcn/here-and-nowhere-else  . Grasses too can show ecotypal variation – just look at how Stace 4 separates up the red fescue aggregate. And it wouldn’t be a piece of writing on variation without the many microspecies of dandelions being mentioned, would it?

However, there is no robust scientific evidence that a seed mix from a limited genetic collection bulked up commercially (i.e seed produced by a seed firm) will create an equivalent grassland community (e.g. MG5) which is as good as or better than using local seed from sites which show a “long continuity of ‘traditional’ management” (ancient grassland) and yet using commercial seed mixes is what is happens generally for creating new grassland habitat. I’m using HS2 as a case study to check what current official conservation practice is – HS2 don’t record the seed source for new grassland communities and only specify that it create a similar plant community (FOI-19-3407 – contractor takes decisions within guidelines given; I haven’t been in contact with the contractors yet) and government departments do similar except in large projects like https://www.devonwildlifetrust.org/what-we-do/our-projects/culm-grassland-natural-flood-management-project for the Environment Agency and for Natural England the High Weald Landscape Trusts Weald Meadows Partnership (WMP) where local seed is used.  It may be that no-one has done any such scientific comparison, but I cannot see how a seed mix of limited genetic variation can ever be a better way to start a new grassland community than green hay from a local ancient grassland and a seed mix is definitely not conservation for England’s grassland plants.

I’ve not been able to find any data on comparative costings between using a seed mix and local seed, and I rather doubt anyone has yet put a cost on ‘loss of genetic diversity to future generations’. If we are in an era where we cost our local biodiversity in monetary terms then this lack is rather glaring. I would suggest that using local seed is the cheaper option as it conserves local habitats (they become needed for their seeds and so would be looked after better) and frequently the cut hay from such sites is surplus to requirements and therefore costs little more than transport and someone to spread it around the recipient site.

Given the willingness of the environmental agencies to ‘work together’ (a euphemism for there being no public money to achieve their objectives; how often have you seen road building requiring cooperative action of local volunteers or charities to lay tar-mac? Well quite.) then using local seed for habitat creation could easily be written into any guidelines and should be, but I suspect it will take legal action to force this government to change. It might even be that the chair of Natural England thinks legal action is required too, for I notice he has sensibly been publicly vocal about how funding cuts have prevented Natural England from carrying out their 500 or so statutory duties or responsibilities properly https://committees.parliament.uk/committee/62/environmental-audit-committee/news/127536/natural-england-finances-squeezed-by-government-making-biodiversity-protection-challenging/    Do his comments now put the legal responsibility of conserving England’s biodiversity back onto Defra or the Treasury and away from Natural England? I hope so because we really do need the experts within Natural England and the diversity of training that only they can give our future experts.

UPDATE 18 February 2021

Thanks to Miles King who let me know that Margaret Palmer wrote “A Strategic Approach to the Conservation of Plants in the United Kingdom” in 1997 https://www.jstor.org/stable/2404765?seq=1 for the statutory nature conservation agencies and he wrote about a “plant conservation strategy : a future for Britain’s wild plants” via Plantlife the year before in 1996 https://www.aspergillus.org.uk/books_and_theses/plantlife-link-plant-conservation-strategy-a-future-for-britains-wild-plants/ which is not currently available digitally.

NOTES

*I wondered if it was just plant conservation but it may be to do with larger populations as I asked Defra (EIR2020/22996) if there was any written record that they had assessed whether the eradication program they are undertaking of the legally-protected mammal the badger would destroy any of the genetic variation present within the UK population. There was no written record, so I have to assume no genetic assessment was carried out prior to killing all the badgers in the specified areas of the country; perhaps that was the idea – you can’t find what you don’t look for?

**since then two new but small populations of dyer’s greenweed have been found in the area, one on private land and one on land of unknown ownership.

The answer for TO2018/27538 was given to me at the end of January 2019 and Natural England also gave me a contact to discuss the issues I’d raised. I haven’t been in contact yet because I’m making sure I’ve got enough evidence for the things I think should be changed in England’s conservation policy first. This blog is also me thinking out loud about what I want to write in my book and seeing what the weaknesses are to my arguments. If you are in Natural England and reading this, I’ll be in touch eventually: I’m slow, sorry.

The practicalities of not cutting road verges

With the success of Plantlife’s rural road-verge campaign for more sympathetic vegetation management (100,000+ signed to the petition) https://plantlife.love-wildflowers.org.uk/roadvergecampaign and their excellent guidelines https://www.plantlife.org.uk/uk/our-work/publications/road-verge-management-guide  you might be wondering why it doesn’t just happen, after all it seems such an obvious thing to do and there are no down-sides, right?

Wrong, unfortunately, there are still large numbers of people complaining about the weeds/the grass not being cut and it looking a ‘mess’ particularly in urban areas and that makes a difference; scroll below the article to see comments  https://news.dorsetcouncil.gov.uk/2019/06/17/our-roadside-verges-a-fine-balance-to-strike/

A good summary of the problems that councils have is here, https://connectingfornature.wordpress.com/2020/05/27/nomowmay-a-discourse-on-the-complexities-of-local-authority-grassland-management/  and in summary it is essentially no money, no time, the wrong equipment, and what do we do with the long grass when we do cut it?

In Middlesbrough the council was proposing to save money this year (£60k?) simply by changing the interval time between cuts in urban areas from every 11-13 days to every 13–15 days. This would mean seasonal staff don’t need to be hired in summer and the grass is cut 11 times a year rather than 13. It was purely a way to save money, because government cut-backs have been particularly severe for the area, but any flowering plants get an extra 2-4 days to bloom so there are small biodiversity gains: It can also look ‘messier’ (I use ‘more relaxed’ as a description, but then I prefer it).

Ten years or so ago the local ecologist at Darlington Council was able to instigate long grass areas inter-spaced with regularly mown paths and larger mown play areas because a local farmer was willing to cut the long grass at the end of the summer, make hay with it, and then cart it away.

And that is the crux of the problem with long grass…it must be taken away when cut, and almost all Councils don’t have the equipment to do that.

Dorset Council is one exception and they have been using cut and remove mowers that cost around £35 to £40k (see http://www.grilloagrigarden.co.uk/fd2200_4wd ) and the council state this type of mowing is of value particularly in urban areas where they have in places been able to reduce the number of cuts from 7 times a year to 3 times a year. The reason – continually removing the cuttings lowers the fertility of the soil; vegetation grows more slowly in poor soil and so it needs cutting less often. As it happens, low fertility soil is just what is needed for growing native grassland wildflowers. For once a win:win situation, the council needs to cut the grass less frequently so it saves money every year and residents get a more biodiverse local environment. An illustrated .pdf from Dorset County Council Environmental Advice Team explaining this is here https://butterfly-conservation.org/sites/default/files/2019-10/Giles%20Nicholson%20Dorset%20Council%20-%20Persuading%20decison%20makers%20to%20manage%20verges%20for%20ecology.pdf  Another added bonus is that longer grass grows deeper roots, enabling it to cope better and stay greener in drought events.

The cut grass that is collected can be used either in making compost (though this may have a cost associated with it if waste disposal is carried out by a private company) or to use in prototype electricity or heat generation. Also, if timed correctly, cut grass from species-rich road verges can be used as a seed source to create new road verges.

The best option is to think about management at the planning stage so that each new road verge created uses low fertility soil (sub-soil) and if the soil is seeded with green hay from local heritage grassland habitats then local cultural heritage and biodiversity can be celebrated as well as money saved. The fact that landscape architects, urban planners, and elected councillors have not been doing this speaks volumes on how poor their understanding of long-term green-space maintenance costs, especially given road verges have at least a 50-year lifespan.

Some notes from the Road-verge Conference in Suffolk

On Saturday 29th February 2020 I attended ‘On the Verge of Success. The importance for wildlife of our Roadside Verges’ with about 200 others, 9 speakers & many informative stands.

Firstly to point out what excellent organisation from the Suffolk Naturalists’ Society http://www.sns.org.uk/  and Wherstead Park http://whersteadpark.co.uk/  (who made feeding and watering 200 or so people seem effortless so we could concentrate on speakers and stands).

And secondly – it was a very detailed and fascinating day (which also involved not-plants) so these brief notes are what interested me and are not intending to reflect the whole of the day.

Design of new verges

• Soil fertility is key to biodiversity – low fertility gives high biodiversity coupled with low maintenance costs, because plants don’t grow as much. Any new landscaping specification/design for road verges should use mineral soil or subsoil & no topsoil.
• Spread local green hay & hand-collected seeds and accept it will take time to reach the equivalent of a species-rich grassland and acknowledge that the successional stages will be of high wildlife value too. Manage expectations.
• Don’t create a fast road with narrow verges (splat) or with narrow steep sides (funnel splat). In the Q&A splat of insects on cars was discussed: wider the verge the better and it was thought the level of splat would be below the benefit of increasing biodiversity. Also use as lever to improve/connect surrounding countryside.

Improving existing verges

• Three cut-and-remove targeted in one year makes a big difference with nutrient removal which can be seen in slower and lower grass growth the next year (small ride-on machinery is available to do this & Dorset County Council has just ordered more because it works for them financially esp. for urban areas).
• Can do the above and then scatter common grassland species seed e.g. oxeye daisy to create a more biodiverse sward. Also mentioned was a late cut in spring can give a shorter flowering height in summer (ref. horticulture’s ‘Chelsea Chop’)
• An example shown of turf removal (rolled and placed in hedge base) of a verge and resulting bare soil sown with green hay to give more diverse verge.

Maintenance cutting of verges

• The key here seemed to be if a road verge is a designated Roadside Nature Reserve (RNR) then it should be managed for the reason of designation i.e. a specific plant species/plant community/insect/fungus
• Otherwise variation in heights and timing of cutting throughout the whole of the area being cut, with cut material best removed. Plantlife have comprehensive guides https://plantlife.love-wildflowers.org.uk/roadvergecampaign Even regularly cut species-rich verge can be part of that mix, as can irregularly cut scrubby patches and uncut grass. [Apparently, Dormice live happily on scrubby shrubby road verges in some areas of the country.]

Complications

• Over-riding principle of road verge management is always the safety of road users.
• Who owns what and who is responsible for maintenance is not always who you might think.
• There is (usually) not enough money to manage Roadside Nature Reserves (RNR) without the help of volunteers, despite RNR extent being tiny compared to rest of roadverge network.

Conclusion

I was struck by the knowledge and experience that was available nationally for creation/management of bio-diverse road verges and left feeling enormously frustrated that this is all still at the pioneer stage in practice nationally and not really happening in my patch yet.

Who teaches the people who specify the soft landscaping for new roads and why do they choose to get it wrong every time? (in fairness I should add that Leonardo Gubert from Highways England gave examples of three roads in planning that are going to use green hay, but still, it really should be the norm and not the exception).

And why do the politicians (local and national) always prefer the expensive-to-maintain low-biodiversity option of sowing grass on topsoil and adding trees in plastic protectors?

Something for me to find out locally…

Theresa Villiers’ acres, Rishi Sunak’s ‘taking back control’, Zac Goldsmith’s ‘ramp up’, the very real problem of Teesside International Airport, and the meaning of words.

*updated 29 Jan 2020 at the end of the blog

**updated again 31 Jan 2020 at the end of the first paragraph

I noticed recently https://www.gov.uk/government/speeches/a-vision-for-future-farming that the Secretary of State for Environment, Food and Rural Affairs and MP Theresa Villiers delivered the government’s target for tree planting in the imperial unit of acres,  a measurement once described by an infamous English wit as a measurement of three rods, 9 perches, two pecks and a bushel by two cubits, seven chains and the length of your neighbour’s largest oxen (for nerds…that was a yoke). By contrast, in the 21^st Century, a hectare is 100 metres by 100 metres. Obviously 75,000 acres sounds a lot more than approx. 30,000 hectares given most people can’t envisage either area, but nevertheless I’ve written a Freedom Of Information Request to find out what the government’s official unit of area measurement actually is, and whether Defra uses a different one. ** I was thanked for bringing the matter to their attention and they confirm hectares as the unit of measurement that “the Government intends to use in its targets going forward.”

A small part of the common bird’s-foot-trefoil studded grassland adjacent to the Airport.   Meadow barley can be found nearby.

In my local area the Tees Valley Mayor Ben Houchen campaigned on the importance of using public money to buy the local airport and indeed managed to do so when elected. When I was younger buying privately-owned businesses with public money was called nationalization, but I noticed that the Chief Secretary to the Treasury and MP Rishi Sunak called it ‘taking back control’ in his latest Darlington and Stockton Times column https://www.rishisunak.com/news/ds-column-back-work-and-delivering-north so perhaps the meaning of the word nationalization has been rebranded as ‘taking back control’ and we can expect buses, railways*, etc. to be taken back into control in future; this does rather seem at odds with the Prime Minister’s recent comments about how the UK was made great through championing Free Trade https://twitter.com/trussliz/status/1217064284607451136?s=20  . Counterpoint; it was made great by putting the word Great in front of the word Britain possibly because it was the largest Isle of many – but always tricky to be sure when words have different meanings.

The idea of control is an interesting one. Now that Teesside International Airport is in public ownership then the information about the wildflowers that grow there should be in the public domain. Having good survey data of the botanical composition of the 100 ha of semi-natural lowland grassland within its boundaries would help to see to see how it relates to the other similar grasslands in the Tees Valley. It could even be ancient grassland as some parts are clearly ridge and furrow – I know because I pointed to the evidence needed to have it included on the local Historic Environment Records database. The grassland is important nationally too, being in the top 10 % in terms of size in England, though when I emailed Natural England they said they have insufficient funding to survey it – it wasn’t even on their radar though it is now.

In a Tweet the unpaid and unelected Minister of State Zac Goldsmith asked us all to ‘ramp up our efforts’ in support of Nature https://twitter.com/ZacGoldsmith/status/1179883606606569475 (although at the time of the Tweet he was paid, elected, and Parliamentary Under Secretary of State) and so I did. I emailed Parliamentary Under Secretary of State with responsibility for Natural England and MP Rebecca Pow and asked if the Government were intending to increase the funding for Natural England back to the 2010 level. She didn’t reply, but I was informed by the person who did reply (after the 15 day target but they did apologise) that “grant-in-aid allocated to Natural England from Defra has reduced from £121.1 million in 2014/15 to £85.7 million in 2019/20” and “…overall funding position is close to the Defra group average [decrease] of 23% across the same period”. Sadly, it didn’t really answer my question which is one of the disadvantages of not using a Freedom of Information Request. In fact Natural England’s funding has been reduced to 2/5 of the 2009-10 total  https://theintermingledpot.wordpress.com/2019/07/22/year-of-green-action/ . Perhaps Minister of State Zac Goldsmith’s ‘ramp up our efforts’ means reduce to 2/5 of your effort in 2009-10; maybe I’m being a bit mean there and should say ‘reduce by 23% of 2014/15’s effort’ but, more seriously, the main limiting factor in the protection of biodiversity in the Tees Valley is the lack of resources for Natural England to carry out their statutory function under Section 2 of the Natural Environment and Rural Communities Act 2006

“ensure that the natural environment is conserved, enhanced and managed for the benefit of present and future generations, thereby contributing to sustainable development.” https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/647574/natural-england-framework-document.pdf

Anyway, back to the airport, I wrote to the Tees Valley Combined Authority (who are the Public Body that own most of the airport) to ask about what information was available on the composition of the grassland within the airport boundary on the 16^th July 2019. My email wasn’t answered so I have just written it again as a Freedom Of Information Request and look forward to actually receiving an answer. The Tees Valley Combined Authority commissioned a report costing £17,719 in January 2019 to see if it was viable to sell the site for housing if the airport became financially nonviable in say 20 years and it said the site is worth about £42 million to create a ‘Garden Village’ style housing development  https://teesvalley-ca.gov.uk/wp-content/uploads/2019/01/Appendix-2-DTVA.pdf (starts at p171 of 225) . There are also new plans to put an industrial park on part of the airport land (270 acres – the 21^st Century waves “Hi”)  https://teesvalley-ca.gov.uk/23-6million-agreed-to-kick-start-teesside-airport-international-airport-business-park/ .

All our public grasslands could easily be as rich in locally-native wildflowers as this one adjacent to the Airport

Meanwhile, the Local Nature Partnership have asked through the appropriately agreed procedure that the Teesside International Airport site be designated a Local Wildlife Site as it meets the qualifying criteria for locally important grassland within the Lower Tees Valley; the Unitary Borough having the airport’s main area within its boundaries refused to do so, with the support of the heads of all the other councils. I wrote to my MP about it on the 7^th March 2019 but have not heard back – I actually wrote to all the MPs in the area because I thought they might work together as a team on behalf of the Tees Valley – apparently not, only your own MP can respond or not respond as the case may be. Recently I emailed a Freedom Of Information Request to the Unitary Authority to find out more details concerning why they refused to designate it as it was an unprecedented decision locally, and to ask for a copy of the report that mentioned the decision (it is no longer present at the same address on their website). I’m shall write it all up in my book ‘Finding England’s Ancient Grasslands’ with a chapter all to itself because I think the problems involved in finding out biodiversity information from people who don’t want you to know biodiversity information are pretty much universal in England.

And before I finish, one mention for what the Chief Secretary to the Treasury and MP Rishi Sunak suggests to be a future “key to re-balancing the North-South divide” which is the concept of Free Ports – two words that, as he points out, really mean Tax-Free Ports for Business, but then that doesn’t sound as good does it, not when we hear so much in the news about big companies avoiding paying tax?

*today it was announced that Northern railways will be nationalized on March 1st or as Secretary of State for Transport and MP Grant Shapps put it “Today (29 January 2020) marks the first small step towards the north taking back control of its railways and its people taking back control of their travelling lives.” https://www.gov.uk/government/news/government-decision-on-northern-rail  although I do note that the government seems to be saying in that press release that the problem is infrastructure which is under the control of Network Rail … a public sector body under the remit of the Department for Transport and therefore publicly owned.

Mis-reporting of the data in England biodiversity indicators Priority Habitats 2018

Summary

Way back in January 2019 I wrote to the Office for Statistics Regulation about the inaccuracies I thought were present within the Defra statistics for Lowland Meadow Priority Habitat; they agreed with my points and wrote to Defra asking them to make changes to their presentation of their statistics.

Defra wrote back to me at the end of September 2019 as they had promised (I’ve just not had time to write it up as a blog until now) to explain the source of their statistics more clearly and to say that they had added in extra information to the presentation of their statistics. (I’ve had this information before from them through previous email exchanges, but I wanted it stated in official documents because that is the official reference point for everyone quoting or using the statistics).

“The process of mapping inventories in England rounds areas up to parcel level, is based on old survey data so doesn’t reflect recent changes, and takes a broader definition of ‘grassland’ – including partially degraded and less species rich grassland than would be considered for designation. Overall, this leads to an overestimate of Priority Habitat cover in England.”

It was that “overestimate” that I was concerned about; the official government figure for Lowland Meadow Priority Habitat 36,129 ha, the reality is probably closer to 8000 ha and I say probably because no-one actually knows.

Why does this matter? If we are to conserve the genetic depth and breadth of our native grassland species, we must use seed from these sites and not from seed packets/commercial seed outlets in order to create new grasslands. Species-rich grassland acts like a glue that holds all the other habitats together to form a functioning ecosystem – destroy the glue and your ecosystem will function badly.

No doubt you will have noticed all the concern about the amount of ancient woodland the HS2 project will destroy. There is over 300,000 ha of ancient woodland in England but under 8000 ha of Lowland Meadow of which HS2 will destroy 1% or 80 ha (HS2 figures); of that Lowland Meadow Priority Habitat we don’t know how much is ancient grassland because there is no official definition of ancient grassland to assess it by.

The government has no plans in the future to map the extent of either known Lowland Meadow sites or to look for currently unknown sites other than a vague promise to improve the quantity and quality of the data, but I have been informed that they are developing drone technology. Currently Natural England have insufficient financial resources to check existing grassland SSSIs (I’ve asked and have local evidence) and the ministers at Defra have no plans to increase Natural England’s funding (I’ve asked that too). The government has no other public servants with sufficient expertise and experience to assess the most important parts of our shared natural heritage other than those employed within Natural England.

My thanks to Ed Humpherson and other team members at the Office for Statistics Regulation for their help with making government statistics more accurate.

 

Full details as below

This all grew out of my inability to understand government statistics for the extent of the Priority Habitat Lowland Meadows and I wrote about previous replies to my questions in this blog https://theintermingledpot.wordpress.com/2018/04/26/estimates/

The response from Ed Humpherson, Office for Statistics Regulation to my email regarding the Defra statistics can be found published here https://www.statisticsauthority.gov.uk/correspondence/response-to-england-biodiversity-indicators-statistics/

And there is a link to my original email questioning the quality of the data Defra were producing at the end of his response.

 

Email from Defra received 30/9/2019

“Thank you for getting in touch with us last year to highlight the differences that exist in the reported areas of lowland meadow grassland across England, and for giving us the opportunity to improve the quality of our priority habitats indicator.

I am aware that the Office for Statistics Regulation (OSR) have been in touch with you regarding your concerns and I can confirm that we have implemented the recommendations they made to us during the 2019 update of our Biodiversity Indicators. These indicators were published on 5 September and can be viewed here: https://www.gov.uk/government/statistics/england-biodiversity-indicators

I am sorry for the time it has taken for me to write to you about the differences in the reported areas of lowland meadow grassland having committed to do so earlier in the year. We have been working closely with colleagues in Natural England and the Joint Nature Conservation Committee to address the issues you raised, and I am now in a position to update you on the outcomes of this work.

As you know, there are several sources of published data for the extent of priority habitats in England, including: (i) those data based on the Biodiversity Action Reporting System (BARS); (ii) those in the 2013 priority habitats inventory, published by Natural England and used in the England Biodiversity Indicators (2a – Extent and condition of priority habitats); and (iii) those used for the selection of biological SSSIs. Given that BARS has now been archived, we have focused our efforts on providing additional clarity for the latter 2 sources of data.

In summary, the 2013 priority habitats’ inventory published by Natural England and used in the England Biodiversity Indicators covers 24 priority habitats. It addresses problems with the original Biodiversity Action Plan (BAP) priority habitat inventories by moving from multiple habitat layers to a single layer based on Rural Land Registry polygons (derived from OS MasterMap). In bringing the existing inventories into a single layer with no overlaps, a set of criteria were used to assign one main habitat (or no main habitat) to each polygon. Where other habitats may be present in the polygon, e.g. as part of a mosaic, these are attributed as ‘attribution habitats’. The process of mapping inventories in England is also based on old survey data so doesn’t reflect recent changes; it also takes a broader definition of ‘grassland’ that includes partially degraded and less species rich grassland than would be considered for designation. Overall, this leads to an overestimation of Priority Habitat cover in England, especially for MG5 communities (unimproved neutral grassland, including hay meadows) that are a subset of the Lowland Meadows Priority Habitat. Despite this overestimation, the 2013 priority habitats inventory map is still considered to be the best available national source of extent data for indicator 2a as it is the only one that allows for an assessment of how the condition of these priority habitats has changed over time.

The England Biodiversity Indicators (2a – Extent and condition of priority habitats)

Additional text based on the above has been added to the fiche for indicator 2a in order to explain why the areas of priority habitat in this indicator differ from those found in other sources.

The extent measure for indicator 2a shows that there are 1.87 million hectares of terrestrial and coastal priority habitats recorded in the 2013 priority habitats’ inventory for England; they represent around 14% of the total land area of the country. The 2013 inventory does not allow for assessing changes to the extent of these habitats, as changes to the inventory itself would represent improvements in current knowledge of the extent of priority habitats, rather than actual changes in the extent of those habitats. Furthermore, although there have been subsequent revisions to the priority habitats’ inventory, indicator 2a consistently assesses changes in the condition of habitats reported in the 2013 inventory.

This condition assessment is used to measure progress towards one of the higher-level outcomes from ‘Biodiversity 2020: A strategy for England’s wildlife and ecosystem services’ – to achieve “… 90% of priority habitats in favourable or recovering condition”. The most recent assessment shows that as of 31 March 2019, a little over 1.25 million hectares of priority habitats were in target condition. This equates to 66.9% of all priority habitats in a favourable or unfavourable recovering condition. Two of the 24 habitat types achieved or exceeded 90% of their area in favourable or unfavourable recovering condition, with a further 10 achieving or exceeding 80%, the target value for each individual habitat.

SSSI Guidelines

The following paragraph has been added to the guidelines for the selection of SSSIs. It has been linked to sections 4.10 and Annex 1 of chapter 3 of the report. The additional text explains why the areas of priority habitat in the SSSI guidelines are less than those reported in the England Biodiversity Indicators (2a).

“These areas are a subset of the national Priority Habitat areas used for England Biodiversity Indicator Report (Indicator 2A- Extent and condition of priority habitats). The process of mapping inventories in England rounds areas up to parcel level, is based on old survey data so doesn’t reflect recent changes, and takes a broader definition of ‘grassland’ – including partially degraded and less species rich grassland than would be considered for designation. Overall, this leads to an overestimate of Priority Habitat cover in England. This is particularly apparent for MG5 communities that are a subset of the Lowland Meadows Priority Habitat. While extent may differ, the England national inventory maps (used in England Biodiversity Indicator reporting) are a good indication of the location of known high quality sites.”

I hope this provides the additional clarity you were looking for.”

 

My reply on 8/10/19

“Thank you for taking the time to write to me on this issue.

I try very hard to understand and to consider what is written to me in reply to my questions and I fully appreciate the financial restrictions that you must work within, especially given the current political situation.

I have summarized what I think you have written to me:-

36,129 ha is the official government record of the extent of Lowland Meadow Priority Habitat in 2019; it is known to be an overestimate and to have been out of date since 2013 as the information it was based upon was out-of-date when the digital layer was created.

BARS has been archived and so data associated with BARS in regard to Lowland Meadows is no longer used in an official government capacity.

Defra uses the 2013 data set because it enables a condition assessment for Lowland Meadow over time and it is the best data set available for accurate location of the habitat.

The data that Natural England use regarding the extent of MG5 in England as evidence within a SSSI designation is a subset of Defra’s 2013 dataset [this bit is a puzzle as if Natural England have access to data at a higher resolution, then presumably they could share it with Defra, so I am assuming that it can’t be used because the condition assessment would not apply, except if a condition assessment applied to a larger area then it would surely apply to the smaller area within the larger area too? It may be that as I research further I will uncover the answer to that one] and I am inferring that the MG5 data is accurate because it is used as evidence in a legal situation.

I have noted that written within the 2a document it says that work is being carried out on improving the “quantity and quality of data on threatened habitats” and that this will be introduced at some unspecified date in the future.

I’m sorry that I have kept pressing you on this matter when I am sure you have little time available, but I do think it is important to have a clear government record on the state of our shared cultural heritage habitats, particularly given the Government’s continual reduction in funding for biodiversity and biodiversity expertise. I’m currently writing a book on England’s ancient grassland and in it feel I need to be able to explain clearly how the government officially records the Lowland Meadow Priority Habitat (within which some ancient grassland is a subset) and I don’t want to misunderstand or misrepresent the government’s official position, though obviously I will discuss how confusing it has been to understand it.

Many thanks for making the changes to the official record”

 

For further information on the SSSI problem see https://theintermingledpot.wordpress.com/2018/09/10/struggling/

How much can we influence the future we want?

I wrote this piece in April 1997 for a local environmental residents group of which I was part. After a wide-ranging discussion about the future we wanted to aim for this was a way of imagining how we thought that future would turn out … a way of setting ourselves local goals to achieve. The group has indeed achieved much from wildflower and tree planting, investigating local heritage, adding public art, improving routes to local schools, and the ever-ubiquitous litter-picking (and much more!).

Acklam 2020

The year is 2020. Mrs Jones is looking after her grandson, George, for the week. We catch her mid-conversation with the home computer …

“… put in our regular order for fruit and veg. I think. Is there anything new in stock?”

“New variety of coloured leaf lettuce and the first of the local new potatoes.” Replies the home computer in a pleasant neutral voice.

“Hmm, well I’ll have a look when I get there. Ask for the order to be ready by ten thirty, I’ll pick them up then, please. Order to the supermarket …two energy-saving lightbulbs. Again I’ll pick them up at ten thirty. Automatic payment of both orders.”

“Transaction complete”

Mrs Jones goes out into the back garden and spies George sitting quietly, apparently transfixed by something in the garden pond. “Come on George, lets go to the Resource Centre now, you can watch the frogs later. They won’t run away.”

“It was watching me, Gran, and blinking. Why do frogs blink, Gran? And sit in ponds all day watching people?

“Er … perhaps we can find out at the Resource Centre. Would you like to go for a walk by the beck to see the birds and wildflowers?”

George looks thoughtful and chews on his bottom lip. “Yes but can we go to the playground too Gran?”

“The adventure playground by the Scout hut, or the swings and slides at the Sports Centre.”

“George’s eyes light up. “Where we went on the evening and saw the hedgehog?”

“Sports Centre it is. Before we go, come and help me put the bottles and jars in the wheelie bin because the bin men are collecting glass to recycle this week. Paper is next week, then plastic. It’s so we can help the environment and save money too, George.”

George nods in understanding whilst putting a bottle on the right side of the bin. They had talked about this at school and he knew all about it, though was a little unsure quite who Mr Environment was and why he controls the world.

Mrs Jones shouts that they expect to be back by one-ish to the home computer, which locks the door as they leave. George holds his Grandma’s hand and they set off down the road.

“Oh look!, wave George: it’s Paul and Susan with the new baby on the bus, those new electric buses are so quiet I never heard it. Would you like to go down town this week, George? Ever since someone redesigned the buses you can get on with a pushchair and don’t have to climb those steps … how we all put up with it before, I don’t know. It’s not often we use the car now that buses are so convenient and cheap.

“Tut, tut, someone’s dropped a sweet wrapper. We don’t get that happening much nowadays. I’ll pop it in the bin at the shops, won’t take a minute. Yes I know all packaging is biodegradable now, but it doesn’t look nice and we can’t have that, can we?”

George shakes his head and starts hopping up and down on one foot, as you do.

They pick up some books and a computer disc at the Resource Centre and set off towards the shops. The street approaching the shops is lined with trees, giving an attractive dappled shade underneath. George jumps from one sunny patch of pavement to another. Mrs Jones waves to a friend.

“Hello David. How are you? Don’t the shops look attractive? Covering them with climbers and putting up some lovely hanging baskets was such a good idea. And thank goodness we don’t need those metal shutters now, they made it look really grim, didn’t they? We’re just off to collect our shopping. Did you have yours delivered today? I thought so. See you later.”

The shopping is all ready to collect and Mrs Jones decides to have some new potatoes as well.

On the way to the playground they see the local policeman, Mr Wilkinson, on his bike and wave. At the Sports centre George rushes to the slide climbing with great glee, and Mrs Jones spots Mrs Thompson, child-minding for one of her neighbours, sitting on one of the benches, and settles down for a chat.

Do you know I was just thinking how little dog dirt you see nowadays. The times when I had to clean our Annie’s shoes when she was young. It’s so much nicer now dog owners are more responsible.”

“Funny you should say that Mrs Jones, because I’ve been sitting here admiring the wildflowers around the edge of the field and thinking you never saw that thirty years ago. And I hear the council save money by having the grass cut just once a year, which can’t be bad? Oh and that reminds me, the home computer tells me Mr and Mrs Peters are having a Garden Open Day. They never seem to do any work in their garden and it always looks interesting. Apparently it’s all down to choosing the right plants and using homemade compost. Everyone is copying because it’s so much easier and cheaper. I’m definitely going, anything that saves time in the garden has to be a good thing as far as I’m concerned.”

They continue, deep in conversation, but each with half an eye on their respective charges.

Meanwhile, George is busy propelling himself as fast as possible, down the slide on his stomach. Acklam is a happy place to be.

Our vision of Acklam in 2020 is of a place where individuals make small, easy changes to their lifestyles, to a more sustainable way of living, and it becomes so comfortable we can’t imagine how we managed any other way.

*****

Looking back, it’s interesting to see the things I got right – the easy access buses, computer speech recognition, ordering shopping online, home delivery of food shopping as well as self-collect, more stocking of local produce (though not as local as I was envisaging), recycling collection on different weeks, environmental education at schools. The Resource Centre in the scene is the local library – it is still open, well used, and has a separate computer room for those without access to the online world; I guess if I were writing the piece now Mrs Jones would have used a search engine of her choice on her phone to find out about the blinking frogs.

Things that will be here soon are electric buses, and biodegradable packaging for sweets.

I didn’t realise that computer information would be delivered through fibre-optics, we did have a police support officer in the area who used to ride around on a bike, but he has long since gone with all the cutbacks due to poor government regulation of the financial services industry leading to austerity. Car use has increased, and the buses are not cheap to use.

Where I think we’ve failed so far have been; attitudes to dropping litter remain unchanged, dog-dirt is still a problem although often now packaged in a small black plastic bag and many more people keep dogs now, the standard of gardening has not improved, and lack of wildflowers in urban areas. And I like to think that now the other childminder could have been Mr Thompson, but I doubt there is a fifty:fifty chance that a childminder would be male.

The shops fell into disrepair and are due be demolished. There is no local playground, but the beck is still there with areas of uncut grass more trees and a few more wildflowers; it’s a much more interesting place to play, though perhaps for children older than George.

 

 

 

The Glover report on national Landscapes, a brief review

The Glover report on National Parks and Areas of Outstanding Natural Beauty (AONBs) (see terms and refs here https://www.gov.uk/government/publications/designated-landscapes-national-parks-and-aonbs-2018-review/terms-of-reference ) was published today https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/833163/landscapes-review-final-report.pdf .

Right near the start of the report is a quote “The United Kingdom is now among the most nature‑depleted nations in the world” by the last Secretary of State for Defra and a member of the government of the fifth largest economy in the world that reduced the amount of money to our national nature experts (Natural England) by 3/5 in the last ten years. So within this context, the report is pretty much about how to refurbish the deckchairs as cheaply as possible, re-arrange them to make them look nice and possibly repurpose them as nature appreciation opportunities. A bit flippant as a summary perhaps, but fair.

I was taken aback when I read “There is much debate, and not enough data to say for certain, whether the state of nature in national landscapes is better, or no better, or even worse than it is elsewhere. In the end, this is a fruitless discussion.” – an astonishing point to make if the function of National Parks is to protect their nature … and bluntly, if it’s not monitored or obviously better, then National Parks have failed in their statutory duties and our legislators have failed too in holding them to account or funding them sufficiently. That should be said in bold not dismissed as a fruitless discussion.

To recommend setting up a new “National Landscapes Service” to monitor their nature when we already have an existing independent national nature-monitoring service seems somewhat lacking in knowledge of how to obtain best value for money. And I do wish reports would stop talking about tree planting…trees do not have to be planted. If the required result is increased tree cover (as mentioned in the detail of the report) then say so in the summary because language leads our expectations and tree planting is rarely good conservation. (see https://theintermingledpot.wordpress.com/2019/08/15/sow-trees-for-conservation-plant-trees-for-timber/ ). For nature recovery we need to increase species-rich grasslands and nutrient-poor wetlands, not trees; increasing tree cover is a climate change issue not a biodiversity one.

 

The perennial issue of the conflict between Natural Beauty and nature conservation was not really tackled but perhaps is not within the remit. Our current cultural preference for neatness, bleakness, or hedges/trees everywhere is not good for nature conservation. The much ignored habitat of coppiced scrub on species-rich grassland or heathland needs a return too. The focus on SSSI monitoring was odd given we also have data on Local Wildlife Sites and could not some existing measures of recording change in biodiversity that are occurring nationally be used (the subset belonging within National Parks and ANOBs) rather than asking for another set to be created that won’t be funded properly by government? There is so little money the requirement to monitor SSSIs every 6 years has had to be dropped.

 

It’s a long report which I doubt many will read fully (I skimmed only, but it has still taken me most of the day to write this although I did do the ironing at one point) and for the most part it seems fine, thorough, detailed and with interesting case studies, wanting things more joined up, more investment, more ‘more’ generally, etc. all things that will need paying for, although some of the ideas are extremely subversive –  “Proposal 8: A night under the stars…” because briefly taking a child somewhere beautiful where richer people live and then dumping them back into a poor polluted urban environment afterwards is pretty much like saying “society doesn’t care about where you live but we care you should know how lovely other areas where people live are”. Coolcoolcool. What could possibly be wrong there? Though the report gave only positive feedback examples so perhaps poor urban citizens are suitably grateful and clutch their forelock appropriately or children are not cynical. And some are surprisingly new age “Proposal 17: National landscapes working for vibrant communities”…there is no more…that is the proposal – anyone have a vibrancy scale we can borrow? That is perhaps unfair, but I think in the detail I would have liked to see some analysis of the expected large numbers of soon-to-be-retired/job changing farmers and their uneconomic farms as a result of EU Exit (that Defra has written about and is expecting) on national landscapes, and how that farmland is to develop in future given the huge influence it will have on those national landscapes. And in the same section I was much amused at the need for the Conservative government to recognise the importance of council housing or, as it is re-termed “National Landscapes Affordable Rural Housing Association”. There is a similar ideological anomaly proposed in having a centralised body to coordinate seeking funding with commercial sponsors rather than letting all the individual national landscapes compete and innovate in the market-place so people can choose which one they want to visit…like schools do, right? Welcome to the North York Moors, sponsored by INEOS…hmmm not sure that’s going to work.

And finally, I struggled to work out what was being described in the report until I looked at the glossary

• “national landscapes” – used to refer to National Parks and AONBs together
• “National Landscapes” – the term we recommend is used for AONBs in the future. We continue to refer to AONBs as AONBs in this report to avoid confusion.

And also talk of “our landscapes” which is possibly a shortened version of ‘national landscapes’, though this is not glosserized. I think we can be sure though that it is not the same as national landscape in the singular which clearly would refer to the whole of the different landscape types within England, right? And obviously not to be confused with National Landscape Character Areas (NLCA).

Although putting “areas” at the end, such that we would have “National Landscape Areas” so we know we are referring to an area in England designated as important in regard to the nature of the landscape or landscapes within that area may have helped;  I am still not convinced it is the right term. In the past I would have commented that scientists wouldn’t have made such a mess of using or choosing a designated term, but since finding Defra, Natural England and the JNCC all have different working definitions to record ‘Lowland Meadow’ I think the issue is one of the inherent difficulties of thinking of wider implications of language use. Conservationists will be well aware of the confusion that occurs when one meaning of a word is rebranded and repurposed for a completely different thing that looks similar and subsequently confuses the general public, of which “Pictorial Meadow” is the classic modern case.

 

As always with government reviews of this sort the massive extinct auroch in the room is money. None of the new proposals are costed, even a vague yearly cost, though we find that the total amount of money spent yearly is £55.4m to which the national lottery adds approx. £16m for projects. Context; Natural England get <£100m to cover the whole country, the Arts Council distributes £576.5m.

The conclusion to the report felt rather more like a relentlessly positive postcard comment from someone who has met some really nice people on holiday than say, a conclusion to the report. The scarcity of funding being crucial, against a background of biodiversity loss, was evidently not something to conclude – perhaps it just went without saying.

So, fitted within a context of relentless cutbacks in nature conservation, because that is what the present government sees as the most appropriate response to facing an environmental and biodiversity crisis in one of the most nature-depleted nations in the world, I can see little hope of anything happening but a confusing name change for our n(N)ational l(L)andscapes (previously partly known as the artist ANOB) within our national landscape.