The neoliberalisation of nature conservation

ADDENDUM - March 2013

Natural England keeps it large

Follow-on article

The moral corruptness of Higher Level Stewardship, Aug 2013

An un-endearing trait of Natural England since its inception in 2006, is in its use of self-congratulatory news releases. I noticed this early on – the cult of the relentless good news story, and which apes the self-aggrandisement of the conservation industry. You can understand this of the conservation industry, dependent as the voluntary sector is on raising its profile so that it has success in securing public sources of funding, and which far outweighs its income from membership, but why so unctuous from Natural England when their funding as a statutory, non-departmental public body is part of the Governments budget every year? Perhaps it’s because of a key performance indicator, agreed with DEFRA, that an outcome of Natural England’s work is that “People are inspired to value and conserve the natural environment” (1). A requirement of the indicator is that more people understand the benefits of the natural environment, and engage with and take action to protect and enhance it. Here’s one of the benefits of protection of the natural environment that Natural England recently flagged up. They lauded the tenth anniversary of the Lundy No-Take Zone (NTZ) the first ever area of sea around England where exploitation was removed, and where there has been proven species recovery and spill-over benefits (2):
“Ten years on, Lundy has helped establish the foundations for marine conservation nationally and is a great example of a marine site managed using the most up to date science and evidence to inform decisions”

You might want to contrast the evident success of this NTZ with the lamentable progress - and Natural England’s malign influence on that progress - on the designation of reference areas in the Marine Protected Area (MPA) network for England, or in fact any MPAs at all (3). Reference areas are the less-threatening, weasel-word terminology that highly protected marine reserves such as NTZs have now become known in the corporate world of nature conservation. This from the Ecological Network Guidance produced for the Marine Conservation Zone Project by Natural England and Joint Nature Conservation Committee (4):
“Within such highly protected (or reference) areas, removal of anthropogenic pressures should enable features to achieve their reference conditions, representing the unimpacted condition of a feature”

Another recent gush in a news release from Natural England is about Higher Level Stewardship (HLS) and which constitutes a logical fallacy (affirming the consequent) on the effectiveness of this agri-environment scheme, just because it announces that HLS has reached a major landmark now that the 10,000th agreement has been signed (5):
“HLS agreements now cover a record total of more than 977,000 hectares of England and represent an annual investment of over £165m each year into the rural economy; helping farm businesses throughout England generate economic growth and support a healthy and wildlife-rich environment”

This financial benefit for farm businesses from agri-environment funding, which is supposedly for income forgone (see later) is emphasised in another news release from Natural England, trumpeting that the area covered by all levels of Environmental Stewardship has hit a record high at 70% of England’s available farmland (6). We get a corroborating quote in the news release about this benefit from Jim Egan of the Game and Wildlife Conservation Trust:
“The vast majority of farmers and land managers view support for the natural environment as part and parcel of running productive farm businesses and the news that over 70% of England’s farmland is now covered by an agri-environment agreement is a very positive result”

It seems there is no shame in the farming and sports shooting industries for having to be paid to mitigate the effect of their activities on the natural world, which many would consider should be a cost they should bear anyway on their business, but then Natural England has always found ways to put more money in the pockets of farmers so that they don’t have to spend their own. Thus, so that England can comply with the EU Water Framework Directive in reducing the level of diffuse pollution in rivers, groundwater and other aquatic habitats caused by farming operations, Natural England runs Catchment Sensitive Farming, a capital grants scheme that funds farmers to erect fencing along farmland watercourses to prevent livestock entering the water; put roofing over manure storage areas and livestock gathering yards to prevent run-off from rain; separate clean and dirty water in farmyards; install rainwater harvesting equipment; and create sediment ponds and install bio beds and sprayer wash-down areas to reduce pesticide run off into watercourses (7).

The heather farmers and HLS

The nonsense of agri-environment subsidy is seen at its sharpest in those fake farmers of the conservation industry, especially the heather farmers, and where my ire is predominantly targeted, since they also trouser this funding largesse, but don’t have the excuse that they are producing food nor, in the main, setting up wildlife to be shot at for fun – although the RSPB are not blameless in the latter with their cosy relationship on some of their reserves with wildfowlers (8). The really annoying thing is that the EU’s rural development regulations for agri-environment payments do allow payments to “land managers” in addition to farmers, to apply agricultural production methods compatible with the protection and improvement of the environment (9):
“Agri-environment payments shall be granted to farmers who make on a voluntary basis agri-environmental commitments. Where duly justified to achieve environmental objectives, agri-environment payments may be granted to other land managers”

The regulations also allow “non-remunerative investments” where they are necessary to achieve the commitments undertaken under agri-environmental schemes or other agri-environmental objectives. However, it does say that agri-environment payments can only cover those commitments going beyond the relevant mandatory standards. Of course if the mandatory standards are set low enough, then they don’t ever become a barrier to receiving funding.

The European Court of Auditors carried out an audit in 2011 to determine whether agri-environment schemes are well designed and managed (10). The report noted that € 2.5 billion was spent each year on agri-environment payments, with a total of €22.2bn allocated over the period 2007-13. The report concluded that there was very little information available on the environmental benefits of agri-environment payments, that the objectives were overall too vague to be useful for assessing the extent to which they have been achieved; and that policy was not designed and monitored so as to deliver tangible environmental benefits. England was a case study, but the report revealed a major flaw in that while indicators of success where a part of agri-environment agreements, these were only assessed for a few agreements each year.

A mid-term evaluation of the rural development programme for England was carried out about a year before, where the effectiveness of management options in agri-environment schemes for delivering environmental impacts was evaluated mainly on the basis of prior surveys of beneficiaries plus a review of the scientific evidence (11). An issue for all levels of agri-environment funding was “dead weight”, especially for the Entry Level Scheme, where farmers sign up for options that they would have carried out anyway. There was evidence that land managers opt for the least effort option rather than that with greatest environmental value. In addition, the rural development regulation requirement to base payments on compensation for income forgone also prevents the scheme from offering any incentives to help farmers select more challenging, but more environmentally beneficial options. In relation to HLS, there was some evidence that targeted use could achieve some specific goals, but it was difficult to demonstrate impacts at larger scales. Perhaps the most damning statement in the report is that the evidence for heathland improvement under agri-environment schemes is inconclusive. In searching for more recent evidence of evaluation of HLS, I can find only a research project, commissioned by Natural England, to establish a independent baseline on the condition and extent of features being managed, so that it will enable a future re-survey to validate the success of management, and thus the potential of HLS to deliver expected outcomes (12). You might think it odd, since Natural England have not yet delivered the General Publication and Spatial data of the project, that it is now eight years on from when HLS replaced the Countryside Stewardship Scheme and it has still not sorted a system of evaluation of HLS (at inception, it was under the auspices of the Rural Development Service in DEFRA) (13). It would appear also, that Natural England are a bit sloppy in the way they hand out HLS funding, as the European Commission is clawing back  €4.35m (£3.75m) this year for “deficiencies in the Agri-environment measures” because of non-compliance with EU rules or inadequate control procedures (14).

The sins of Natural England

While it is not in the interest of farmers or the conservation industry to bite the hand that feeds them, Natural England does, occasionally, get to hear criticism of HLS and their overall approach to nature conservation. Natural England has a Science Advisory Committee that meets quarterly, with a role to provide independent advice, challenge and review to the Science and Evidence functions that supposedly drives their every action (15). At its meeting last September, the Committee invited Professor Brian Moss, Liverpool University, to outline his concerns for Natural England and its approach to conservation, in a talk entitled Natural England – four sins and a future? (16). Prof. Moss has a long track record of research on freshwater ecosystems, and particularly eutrophication of shallow lakes, such as his work on the problems of the Norfolk Broads (17). Working at the level of entire ecosystems, his research has lead to an understanding of how different groups of organisms interact, and how freshwater ecosystems behave under pressure from human activities, such as from excess nutrient loads (18).

Reading between the lines, Prof. Moss had some specific issues with Natural England about a Higher Level Stewardship agreement on an SSSI near the coast (could have been one of the Broads SSSIs?) and more broadly on the evidence base that Natural England uses in its land management advice to achieve “favourable condition targets” (19). Explaining the four sins of his title, he criticised Natural England for the following (16):

  • Scientific capacity had been diminished as the workforce had decreased in size

  • Being too focussed on image, less honesty with the public about the environmental health of the planet

  • Following a conservation philosophy that was outdated and potentially destructive, rather than an earth system science approach

  • Being representative of bodies and structures that are inappropriate for the future challenges faced

Looking to the future, Prof. Moss said that Natural England should consider their work in a global context of restoring biomes (areas of the same natural vegetation) that it should move to a more radical, effective zoning of land, away from National Vegetation Class/Biodiversity Action Plan species approaches, and on to ecosystems approaches. He proposed a re-organisation of required bodies along water catchment lines, their action being science led and free from political interference. As I know from my involvement in the IUCN-UK project to identify protected areas in the UK and assign the IUCN management categories (20) this is far too challenging for Natural England, who want to cling on to the command and control interventionist management approach of SSSIs. Sure enough, the Committee rationalised away his proposal, by raising the “constraints of reality” in taking forward a radical agenda when “Natural England has been created by government and has a defined clear remit” (16). Well, as the Governments statutory body to ensure that the natural environment is conserved, and under specific directions from the Secretary of State as to the exercise of its functions (21) then couldn’t Natural England make a case to Government for an earth system science approach?

Large scale conservation

As Prof. Moss proposed a spatial approach to nature conservation based on water catchments, I wonder whether he knew about, and what he would think of, Natural England’s developing interest in large scale conservation? I wasn’t aware of it myself until an email was passed on to me about a meeting that is to take place in London next month. It is being hosted by Natural England, in partnership with RSPB, the Wildlife Trusts, Butterfly Conservation and the National Trust. The premise of the meeting is:
“Large-scale approaches to conservation and associated concepts such as ecological networks are prominent in recent environmental policy in England. We feel that this is an important point to take stock of what we have learned so far about planning, setting up and managing large-scale initiatives, and to look ahead to make the efforts of the many government and non-government organisations involved even more effective and coordinated in future”

Attendance at the meeting is by invitation only, with the intention of “bringing together 100 of the leading thinkers and practitioners from across the wide range of organisations”. It is interesting to contrast the difference in approach between Scotland and England, because there was an event with probably similar content and speakers at the Museum of Scotland at the beginning of February, but it was open to all and not just by invitation (22). Anyway, it didn’t take me long to find out that behind that meeting in London was another research project of Natural England, in combination with DEFRA, Scottish Natural Heritage and the Countryside Council for Wales (23). The project work was being done by the Universities of Cambridge and Southampton, compiling lists of existing large-scale nature conservation initiatives in England, Scotland and Wales, examining the scientific principles that were used by the initiatives, exploring the social, institutional and community aspects, and analysing the environmental outcomes that have been achieved. None of the documentation scheduled for delivery has been released yet, but that meeting is listed in the project outcomes, albeit with a date of two days later.

In search of more information, I found the project details at Cambridge, and which gave the context of the research (24). It points to the approach over the last 10 years of “landscape scale” conservation as developed by the Wildlife Trusts (‘Living Landscapes’), RSPB (‘Futurescapes’), Butterfly Conservation (‘Landscape Target Areas’) and the National Trust, as well as the Integrated Biodiversity Delivery Areas of Natural England. As would be expected, the independent report of the Lawton Committee - Making Space for Nature: A review of England's Wildlife Sites and Ecological Network - was referenced, and which had recommended the creation of new Ecological Restoration Zones that are networked together, as well as the Governments White Paper The Natural Choice: securing the value of nature, which endorsed the idea of large scale conservation through the setting up of Nature Improvement Areas, its version of Ecological Restoration Zones.

As I have pointed out before, an offloading of state responsibility for wild nature to the conservation industry has been going on for some time; that the link between conservation dogma and agri-environment funding has become self-fulfilling; that the conservation industry has become one of the main beneficiaries of this, as it is now the business model on which all nature conservation in England rests; and that it is often based on the transfer of control of large areas of the public realm into these unaccountable third sector organisations, taking away the ability of local people to decide for themselves (25, 26, 27, 28). Thus when I eventually did see that the usual suspects were on the invitation list to this meeting, it just demonstrates that there is nothing like getting the main recipients of agri-environment funding, and who are thus willingly compliant with the conservation agenda of Natural England, all in the same room to talk amongst themselves. As a colleague noted, there are no “non-brainwashed” on the invitation list.

You don't have to be a cynic to realise that these large-scale approaches to conservation are just about networking agro-ecological habitats that have a favoured status under the UK Biodiversity Action Plan. This is exemplified by the obsession of identifying any remnant scrap of lowland heath, or even some figment of distant memory, so that it can be restored by mechanical destruction, and thus provide another heavily-management-dependent stepping stone for presumed heathland species, funded by HLS. This is what "landscape scale conservation" is all about. The same can be said for chalk grassland, driven by the needs of butterflies, which also fuel the obsessive drive for there to be more destruction in maintaining artificial forest edge/clearing habitats in every woodland through coppicing, glades and rides. Then, there are the upland moors, which aren't exactly fragmented, but of course whose impoverished habitats must be maintained in absolutely stupefying extent. Landscape scale conservation is a charter for massive intervention management, and which of course gives a purpose and an income to our conservation industry.

The governance of nature conservation

Interestingly, Adams and Hodge, the two Cambridge professors involved in the research project have confirmed the central role of the conservation industry in large scale conservation in a paper presented at a Biodiversity and Economics for Conservation network meeting last September, noting as well the unwillingness of Government to intervene directly in order to ensure implementation of the Nature Improvement Areas in the White paper (29). They consider this development of large scale conservation areas under the direction of a non-accountable, third sector conservation industry to represent a success of neoliberalism, perhaps even a free market environmentalism in the face of a doctrine of a "lighter state". (Neoliberalism is the transfer or appropriation of state function and state assets to non-state actors – see also my analysis of this above.). However, they think it is too simplistic to attribute the emergence of large scale conservation areas to some spontaneous neoliberal order (29):
“A major factor has been the availability of funding provided for agri-environment schemes under the auspices of the Common Agricultural Policy (CAP). Thus what may appear to be an independent voluntary movement is in fact substantially oiled by the old fashioned largesse of the CAP”

They wonder what the long term implications are for this non-state action in conservation governance and policy delivery, fearing that the neoliberalist approach will only tackle the soft targets of nature conservation, and within its limited capacity and vision, leaving out the areas where there are the most valuable marginal conservation gains to be achieved from increased investment in new institutions and altered land management. It also leaves unresolved the issue as to whether and how any conservation gains that may be achieved are to be sustained in the longer term. Thus they conclude there is a need for a post-neoliberal approach towards nature conservation (29):
“Government needs to move towards a new post
-neoliberal approach that is more interventionist, implementing more formal legal agreements and land purchase to secure conservation land management against serious but uncertain threats”

If I was surprised that the leaders of the Natural England project would offer up such a critique from their research on large scale conservation, then I was also taken aback when I found out what Prof. Lawton, who had led the review of England’s wildlife sites and the connections between them (Making Space for Nature - see above) had written some years ago about the futility of thinking that science would be the arbiter of nature conservation (30 - and see above). He believed there was a fundamental dilemma at the heart of conservation efforts: what do we wish to conserve, and why? At its simplest, it could be the reduction and elimination of human impact in targeted areas to conserve remnants of what is natural. Except that he was reluctant to accept a bench-mark for what that was for any ecosystem, since he considered that they change continuously at all time-scales, and they become more different the further you go back in time. Thus for him, it often became a choice rather than a decision when it came to nature conservation. Lawton gave a very interesting example to illustrate his arguments (30):
“Ten thousand years ago, the major heathland UK National Nature Reserve known as Chobham Common, just a few mile away from Silwood Park, was a barren tundra (ice ages occur infrequently, but with great power). Then, somewhere between roughly 5 and 10 thousand years ago it was progressively birch, pine and oak- hazel woodland, and finally under the combined human impacts of felling, fire, primitive agriculture and grazing it turned into heathland. Now, left unmanaged, it reverts back to scrubby birch-pine woodland. But 'society' has decided that heathland is more valuable from a nature conservation point of view than birch-pine woodland, and Chobham is one of a number of heaths actively managed to maintain and to restore this threatened ecosystem. But the decision has no rational basis in science. We might just as easily have decided that trees look nicer than heather, and changed the management regime accordingly”

I wonder how that makes the people feel who objected to the application in 2011 from Surrey Wildlife Trust to fence off areas of Chobham Common so that it could be grazed in the cause of heathland restoration? Of course, Surrey Wildlife Trust had already received a stonking HLS for the Common in 2010 of nearly a million pounds over the 10 years of the agreement (AG00272604) that will fund the use of their own grazing herd as well as the usual scrub and tree removal (31). The strength of objection to the application resulted in a public inquiry last April, and the objectors were not just crushed by the decision of the Inspector to allow the fencing, but were also astonished that he made such a presumption about the evidence submitted by Natural England, and which goes to the credibility of the inquiry process (32). Martin Elliott, the Inspector accepted that any improvement as a result of the fencing and grazing would be small and would not bring the site into a favourable condition. He also accepted that there had been no indication of evidence given during the Inquiry that could be used as part of any baseline survey or scientific evidence on which any success could be measured. But then he stepped over the line of impartiality (32):
“Whilst the evidence before me is oral and anecdotal, some considerable weight should be given to evidence provided by qualified and experienced witnesses including that from Natural England. The evidence indicates that whilst the grazing will not improve the whole common it will make some contribution to restoring parts of the common to a favourable condition”

So, at Chobham Common, it is the choice of Surrey Wildlife Trust and Natural England to restore heathland, unguided by science, and which was backed up by the Planning Inspectorate.

The ubiquitous wildlife trust

Bitchet Common near Sevenoaks in Kent is another example of this choice of the heather farmers, and an indication of the obsession of identifying any scrap of opportunity for restoration of lowland heath as a stepping stone for presumed heathland species in one of these large scale conservation initiatives– and it will involve the Planning Inspectorate as well in an application for fencing so that grazing can be reinstated on the common. The Nature on the Map system of Natural England shows Bitchet Common to be made up of a narrow area of ancient semi-natural woodland on its NW side; a thin area of replanted ancient woodland to the NE; a block of replanted ancient woodland on its E side; and the rest is deciduous woodland that has probably arisen from natural regeneration in what was the grazing area of the registered common. Units 1,2 and 3 of the One Tree Hill and Bitchet Common SSSI cover all but the block of replanted ancient woodland on its E side, and all those Units are classified for the main habitat of Broadleaved, mixed and yew woodland - lowland (33). That there is a small amount of heather in each of a small area of birch thinning from 1990 in the natural regeneration of Units 2 and 3 is probably what gets the heather farmers excited, but there is no official recognition of it. Thus Natural England’s Biodiversity Action Plan Priority Habitats mapping of the common shows only woodland – there is no heathland shown on this mapping. This habitats mapping is purported by Natural England to be the “best assessment of the distribution and extent (in England) of some of the Priority Habitats that are listed in the UK Biodiversity Action Plan, based on existing, nationally available, sources” (34).

Sevenoaks District Council (SDC) manages the common through a scheme of regulation under the Commons Act of 1899. The Common is located in the Greensands, Heaths and Commons Biodiversity Opportunity Area (BOA)(35) as well as in the area of the Sevenoaks Living Landscape Scheme of Kent Wildlife Trust (36). You might want to keep a count from this point on, of how often Kent Wildlife Trust is mentioned. The BOAs indicate where the delivery of the Kent Biodiversity Action Plan (BAP) is focused (37):
“The BOA maps also show where the greatest gains can be made from habitat enhancement, restoration and recreation, as these areas offer the best opportunities for establishing large habitat areas and/or networks or wildlife habitats”

The statement for the Greensand Heaths and Commons BOA has the following target for Kent (38):
“Pursue opportunities for creation of acid grassland and heathland where this would contribute to the county-wide target of creating, by 2015, up to 145ha in blocks of at least 1ha and no more than 500m from other existing or new semi-natural habitat”

The statement was authored by Kent Wildlife Trust, and the Greensand Heaths and Commons BOA map in which Bitchet Common is located was produced by Kent Wildlife Trust (39). Kent Wildlife Trust is of course on the Steering Group of the Kent BAP Partnership (40).

This target for the Greensands Heaths and Commons BOA was also stated in the SDC Green Infrastructure and Biodiversity report (41). Kent Wildlife Trust criticised the report, which they thought had an insufficient emphasis on habitat creation and restoration, and then made a pitch for the landscape scale approach of its Sevenoaks Living Landscape Project (42). Kent Wildlife Trust must have been upset that their ambitions for habitat creation and restoration, especially for heathland on Bitchet Common, were not supported in the Appendix to that report: Bitchet Common is listed under the Greensands Heaths and Commons BOA as having Acidic Ancient Woodland, Calcareous Ancient Woodland and Ancient Wet Woodland. It is not listed as having Secondary Woodland with relict Heathland, or Lowland Heathland (35). Moreover, in the Kent Habitat Action Plan for Lowland Heath, the areas listed as target areas under Objectives do not cover Bitchet Common (43):
“Significantly increase the extent of heathland, particularly at or close to existing sites at Dartford and Hothfield, and in the Blean and the High Weald”

Conjuring up heath

Irrespective of that, it seems that the Common was identified some time in the last few years as a potential location to make a contribution to the target for heathland restoration in Kent. It is very likely that Natural England will have assisted in this by undertaking a review of notified features on the Common that was kicked off as part of a national review of SSSIs that Natural England is currently undertaking, after the Natural England Board agreed a strategy in 2008 which committed to keep SSSIs under review (44). This review locally will probably conjure up some heathland on Bitchet Common out of thin air, undoubtedly in the areas of natural regeneration of woodland in Units 2 and 3 (see above). The implication of this is that instead of the Condition assessment for those Units being based on a woodland habitat, which is currently in Favourable condition (33) they will be assessed on the criteria in Common Standards Monitoring for lowland heath – and will thus obviously fail, leading to a change in Condition assessment to Unfavourable. This then puts a pressure for heathland to be created in the Units of the SSSI on the Common under the legislation of the Natural Environment and Rural Communities Act 2006 (21) a self-fulfilling result of the change of notification.

I can trace the build up to the consultation that was held with local people about fencing and grazing on Bitchet Common through the minutes of Seal Parish Council (45): how Kent Wildlife Trust had a meeting with SDC regarding Bitchet Common proposals on the 10th February 2012; how four public walks on the Common had been arranged by the Parish Council for March 2012, with the walkers being given questionnaires to complete; that a committee was set up by Seal Parish Council to collect and collate the views from local people about the Common; how there was a talk on “Heath and Woodlands” about the Common on 29 May 2012 at which it was stated that provision of HLS funding was dependent on some or all of the common being grazed, with someone from Natural England at the meeting saying it would be a waste of public money if heathland restoration was carried out without grazing.

The consultation that resulted after the collation of those early views was overseen by a Steering Group whose co-ordinator was none other than Fidelity Weston, the Chair of Kent Wildlife Trust, and who had also been involved in the original parish council committee, even though she is not a parish councillor, and had hosted the walks on the common. The consultation was supported by documents with a pretty formed approach to the management of Bitchet Common as a heathland site (fencing, grazing, tree felling) (46) and with a map for the fencing and grazing proposals having been produced by Kent Wildlife Trust (47). That there had been collusion for some time on the conjuring of heath was revealed in the report of the survey of Bitchet’s flora and fauna which was produced on behalf of Kent Wildlife Trust for SDC in January 2012, but with the survey itself taking place in August 2011 (48). Tellingly, it says that the survey had been done to assist in the preparation of a management plan for Bitchet, and it does make proposals for where trees should be cleared, followed by grazing.

As is usual in so many heathland restorations, these management plans were drawn up well in advance of any consultation with local people. Thus it is not surprising that the November 2012 meeting of Seal Parish Council had an update from Felicity Weston, Chair of Kent Wildlife Trust, that revealed that a petition had been started against the fencing proposals, and that the results of the analysis of the consultation were mixed. As usual, the public who objected to the proposals for fencing and grazing were considered to be under informed about the value of heathland:
“There appears to be a need for a greater understanding of what is trying to be achieved, as indicated by a petition received..........It is therefore felt that considerable more time and effort needs to be put into engaging the local community in the practicalities of wood and heathland management, the value of commons to the local community and the importance of such sites as part of the community`s local heritage. This is beyond the scope of the present steering group and it is therefore agreed that it would be beneficial to look into funding opportunities that would enable more effective and meaningful community and education engagement"

Well, do not be surprised if it is Kent Wildlife Trust that end’s up with that funding for engagement, and it wouldn’t also surprise me that the bill is picked up as a Special Project under HLS funding (49) secured through a rewriting of the large HLS agreement that currently includes Bitchet Common (AG00351070) but which surprisingly has no management options that cover the common. Kent Wildlife Trust may also benefit in other ways from this rewriting, being subcontracted by SDC to carry out the restoration, and may even be the recipient directly of the HLS funding in the revised agreement on the common. Could it be that that rewriting is already ongoing, now that Natural England’s mapping of the HLS agreement shows the common is not covered, when it was last July?

While Bitchet Common is an example of heathland creation/restoration under the neoliberal onslaught of the conservation industry’s landscape scale approach, and driven by HLS, the iniquities of heathland and HLS go much wider, and to other actors (25). I will return to this, with a sordid tale of illegal destruction of reptiles and their habitat on Allerthorpe Common of the Public Forest Estate in N. Yorkshire; the over-grazing of Longmoor Common in Cumbria, resulting in a failure of establishment of the butterfly that was the reason for the fencing and grazing; the payment for grazing (which they are not doing anyway) and for repair of walls (which should be their cost) for commoners around Baildon Moor in W. Yorkshire, and the cavalier use of herbicide spray that risked an uncommon fern on the moor; and what appears to be a fictional premise for the HLS application for Sound Common near Nantwich in Cheshire – all the iniquities revealed only after Freedom of Information requests to Natural England.

Mark Fisher 28 February 2013

ADDENDUM
Natural England keeps it large

Adopting the slangauge of yoof culture, this maladroit attempt at humour is Natural England’s headline title for a feature on its website about the meeting on Large Scale Conservation that took place at the London Wetland Centre on the 27th March (50). The meeting was full of people I would normally cross the road to avoid, but the cheese and pickle sandwiches were good. The wetland centre itself (51) is very much like the wetland nature reserve I grew up next to, where the River Meon reaches the coast in Hampshire, except that the Haven at Hill Head does not have a city by its side (52). I don’t think the birds care either way! I watched a heron stand absolutely motionless by the side of reeds, as I had done many times in my youth. It didn’t move the whole time I was there.

We were told early on in the day that “NGOs have been the absolute pioneers” of large scale conservation and, in terms of resources, it was HLS that had supported their initiatives. And yet the main conclusions of the day had to be that there is no evidence that agri-environment funding delivers benefits at a landscape scale, and that the overlap between different large scale initiatives, mostly NGO-driven (eg. Living Landscapes, Futurescapes, Butterfly Conservation, River Restoration, HLS Target Areas etc) creates a very confusing picture that is evidence of a lack of coordination, the duplication being very difficult to defend - or even explain! I am grateful to Aidan Lonergan, the RSPB's Futurescapes manager for later having the honesty to actually use the phrase “business model” in relation to the activities of NGOs and how they compete for resources.

I had talked about this with Miles King of Buglife the night before. Miles had blagged his way into the House of Lords reception for the European Wilderness Initiative (53) on the back of George Monbiot’s invitation. Miles and I have sparred before (in good nature) about mainstream conservation, but he had his concerns about large scale conservation. He also blagged a place at the meeting the next day, but he left early before the dreaded groupwork. At least he had had confirmation by then of his concerns. It came from an astonishing talk by Dr Jemma Batten, the coordinator of the Marlborough Downs Nature Improvement Area (NIA)(54). Jemma explained that the NIA is entirely farmer driven, and with no commitment for habitat restoration linked to BAP priorities, other than for game shooting purposes, nor for increasing public access. Somewhat ironically, none of the conservation industry NGOs are part of the NIA partnership, except for the Game & Wildlife Conservation Trust. I talked to Bill Adams, a speaker at the meeting, about neo-liberalism in nature conservation, and the transfer of action to the private sector (see above). He pointed to the Marlborough Downs NIA as being an exemplar!

Bill gave a very interesting talk, with an historical perspective on nature conservation leading up to the enactment of the National Parks and Access to the Countryside Act 1949, which he saw cement a “great divide” between the small areas of reserves protected for nature conservation, and the large areas of the national parks protected for landscape beauty. He put up maps showing the areas proposed by the Society for the Promotion of Nature Reserves from 1915, and the scientific areas and national parks proposed in the Huxley report from 1947, and then juxtaposed those with the bewildering overlap of the various contemporary large scale conservation initiatives, indicating that there was truly nothing new. Later, Nick Mcgregor, the principal specialist in landscape ecology in NE, gave greater detail of that overlap for just one NIA, showing a map of the Nene NIA and the encroaching of a Living Landscape, a Futurescape, a Strategic River Restoration and HLS target Areas. Two large priority areas for Catchment Sensitive Farming are just outside the NIA boundary. Paul Selman’s talk was a caution that large scale conservation had to matter to people, and not just the conservation industry. He saw the dominance of the conservation industry in setting up the large scale initiatives, but that the landscapes in these areas need the involvement of communities in their long term care. He said there were many values that could be derived from these landscapes, both material through extraction and recreation, but also the non-material – “landscape experienced through the sole of a shoe”. He wanted to get away from the historicity of countrysides of production to future landscapes that were countrysides of consumption.

The product of the groupwork had great similarity with designing a camel. However, there were comedic elements, such as identifying "charismatic catalysts". Aidan Lonergan proclaimed to know some of these, and thought they were tricky people to deal with! Another was "investing in leaders". The latter may have changed to "leadership" but it was not determined whether that was leadership within an NIA (or other large scale initiative) or whether it was leadership from the NIA. Two recommendations from our group may have survived in recognizable format - I say survived because an individual opinion expressed in the plenary discussion of the recommendations was enough to get changes. What was the point of the groupwork? One of the recommendations was taking away the emphasis on single species in large scale initiatives towards a broader, focal species approach (I did allude to Forest Habitat Networks in my group); and for the NGOs to cooperate in coming up with an overall spatial approach to large scale initiatives, rather than the endless confusion of multiple overlaps that exist at the moment. In fact, many of the recommendations put an onus on NGOs to subsume their sectoral interest if large scale conservation is to have any real value! I expect self interest will be satisfied whatever they do.

31 March 2013

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http://publications.naturalengland.org.uk/file/1185231

(2) Lundy No-Take Zone – ten years on. Natural England 11 February 2013

http://www.naturalengland.org.uk/ourwork/marine/lundyntzfeature.aspx

(3) Protected areas in Europe – Natura 2000 versus national protected areas. Self-willed land January 2013

www.self-willed-land.org.uk/articles/protected_areas_europe.htm

(4) Ecological network guidance, Marine Conservation Zone Project, Natural England and Joint Nature Conservation Committee June 2010

http://jncc.defra.gov.uk/pdf/100705_ENG_v10.pdf

(5) Higher Level Stewardship reaches major landmark as 10,000th agreement begins, Natural England 17 December 2012

http://www.naturalengland.org.uk/about_us/news/2012/171212c.aspx

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http://www.naturalengland.org.uk/about_us/news/2013/300113.aspx

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http://www.naturalengland.org.uk/about_us/news/2012/301012.aspx

(8) RSPB criticised over shooting on reserve, Paul Eccleston, Daily Telegraph 11 January 2008 http://www.telegraph.co.uk/earth/earthnews/3321340/RSPB-criticised-over-shooting-on-reserve.html

(9) COUNCIL REGULATION (EC) No 1698/2005 of 20 September 2005 on support for rural development by the European Agricultural Fund for Rural Development (EAFRD)

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2005R1698:20090101:EN:PDF

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http://eca.europa.eu/portal/pls/portal/docs/1/8772726.PDF

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http://ec.europa.eu/agriculture/rurdev/countries/uk/mte-rep-uk-england_en.pdf

Agreement-scale monitoring of Higher Level Stewardship delivery, Research Project 0033 (12) Environmental Stewardship monitoring and evaluation, Natural England

http://www.naturalengland.org.uk/ourwork/research/register/evironmentalstewardshipmonitoringandevaluation.aspx

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(14) Commission to recover €414 million of CAP expenditure from Member States, European Commission Reference: IP/13/160 26 February 2013

http://europa.eu/rapid/press-release_IP-13-160_en.htm

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http://www.naturalengland.org.uk/Images/NEB-PU27-06_tcm6-27843.pdf

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University of Liverpool). in Natural England Science Advisory Committee (NESAC) Quarterly Meeting Report NEB PU33 03 27 November 2012

http://www.naturalengland.org.uk/Images/NEBPU3303_tcm6-34450.pdf

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https://news.liv.ac.uk/2004/03/01/liverpool-scientists-help-preserve-norfolk-broads/

(18) Professor Brian Moss. The IEEM Medal for Distinguished Lifelong Contribution to the Theory and Practice of Limnology. 23 June 2010

http://www.ieem.net/data/files/Resource_Library/Awards/Awards-Brian_Moss_Citation.pdf

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http://www.naturalengland.org.uk/Images/minutes-september2012_tcm6-34697.pdf

(20) IUCN NCUK (2012) Putting Nature on the Map - Identifying protected area in the UK: A handbook to help identify protected area in the UK and assign the IUCN management categories and governance types to them. IUCN National Committee for the United Kingdom

http://www.iucn-uk.org/Portals/0/PNOTM%20handbook%20small.pdf

(21) Natural Environment and Rural Communities Act 2006 c.16

http://www.legislation.gov.uk/ukpga/2006/16

(22) Science and policy of ecological networks explored, Scottish Wildlife Trust News 13th February 2013

http://scottishwildlifetrust.org.uk/news/science-and-policy-of-networks-explored/

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http://www.naturalengland.org.uk/ourwork/research/register/phdprojects.aspx

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http://www.geog.cam.ac.uk/research/projects/largescaleconservation/

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www.self-willed-land.org.uk/heath_madness.htm

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www.self-willed-land.org.uk/articles/nature_improvement.htm

(27) Contemplation of natural scenes, Self-willed land 6 January 2012

www.self-willed-land.org.uk/articles/natural_scenes.htm

(28) The New Enclosures, Self-willed land September 2012

www.self-willed-land.org.uk/articles/new_enclosures.htm

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http://www.bioecon-network.org/pages/14th_2012/Hodge.pdf

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of conservation biology. New Zealand Journal of Ecology 21(2): 117-120

http://www.nzes.org.nz/nzje/free_issues/NZJEcol21_2_117.pdf

(31) Management Proposals – Chobham Common, Surrey Wildlife Trust February 2010

http://www.surreywildlifetrust.org/files/chobhammngtproposals.pdf

(32) Chobham Common Application Decision COM 231, The Planning Inspectorate 27 July 2012

http://www.planningportal.gov.uk/uploads/pins/common_land/decision/com231_decision.pdf

(33) Condition of SSSI units for One Tree Hill And Bitchet Common, Natural England http://www.sssi.naturalengland.org.uk/special/sssi/reportAction.cfm?report=sdrt13&category=S&reference=1000317

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http://www.natureonthemap.naturalengland.org.uk/help_data_bap.html?refer=map

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www.self-willed-land.org.uk/articles/9_green_infrastructure_and_biodiversity_appendix.pdf

(36) Sevenoaks Living Landscape Project, Kent Wildlife Trust

http://tinyurl.com/cb8srra

(37) Kent Biodiversity Opportunity Areas, Biodiversity – Action for Kent’s wildlife

http://www.kentbap.org.uk/kent-boas/

(38) Greensand Heaths and Commons, Biodiversity Opportunity Area Statement, Biodiversity – Action for Kent’s wildlife 2009

http://www.kentbap.org.uk/images/uploads/Opportunity_Area_Statement_-_Greensand_Heaths_and_Commons_FI.doc

(39) Biodiversity Opportunity Areas - Greensand Heaths & Commons - Map 1 of 2, Kent Wildlife Trust 2009

http://www.kentbap.org.uk/images/uploads/Greensand_Heaths__Commons_1_of_2.pdf

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http://www.kentbap.co.uk/about/our-partners/steering-group/

(41) Sevenoaks District Council Green Infrastructure and Biodiversity, Sevenoaks District Council May 2010

www.self-willed-land.org.uk/articles/8_green_infrastructure_and_biodiversity_topic_paper.pdf

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www.self-willed-land.org.uk/articles/m1_statement_on_behalf_of_kent_wildlife_trust.pdf

(43) Objectives, Kent Habitat Action Plan for Lowland Heath

http://www.kentbap.co.uk/habitats-and-species/priority-habitat/lowland-heath/

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http://www.naturalengland.org.uk/Images/Notification%20strategy%20for%20web_tcm6-15235.pdf

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http://www.sealparishcouncil.org.uk/#/parish-meetings-2012/4559098193

(46) Bitchet Common new management proposals and consultation, Discussion in 'Seal' started by Sevenoaks District Council, Sep 10, 2012 (The links through to the documents on the SDC website are dead)

http://www.sevenoaksforum.com/threads/bitchet-common-new-management-proposals-and-consultation.1479/

(47) Bitchet Common - Map of management suggestions as indicated in written plan, Kent Wildlife Trust 2012

www.self-willed-land.org.uk/articles/bitchetmaptoshowproposedworks.pdf

(48) Bitchet Common Appendix 1: Ecology and History

www.self-willed-land.org.uk/articles/bitchetappendix1ecologyandhistory.pdf

(49) Special projects, Section 2: Option directory for HLS, Higher Level Stewardship: Environmental Stewardship Handbook, Fourth Edition – January 2013 (NE350), Natural England

http://publications.naturalengland.org.uk/file/2816659

(50) Natural England keeps it large, Features, Natural England 27 March 2013

http://www.naturalengland.org.uk/ourwork/landscape/naturalenglandkeepsitlarge.aspx

(51) WWT London Wetland Centre

http://www.wwt.org.uk/visit/london/

(52) Titchfield Haven National Nature Reserve and Visitor Centre

http://www3.hants.gov.uk/countryside/titchfield.htm

(53) London as Europe’s wilderness capital, PAN Parks News, 27 March 2013

http://www.panparks.org/newsroom/news/2013/london-as-europes-wilderness-capital

(54) Marlborough Downs NIA

http://www.naturalengland.org.uk/ourwork/conservation/biodiversity/funding/nia/projects/marlboroughdowns.aspx

url:www.self-willed-land.org.uk/articles/neoliberal_conservation.htm

www.self-willed-land.org.uk  mark.fisher@self-willed-land.org.uk

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