#ActSwiftly: Help us to save England’s wildlife now!

In an unprecedented move, the government has asked the public what they think about the future of national farming policy and planning policy at the same time.

Planning and farming policies hugely affect the landscape and natural world around us. As Sheffield and Rotherham continue to grow, our homes, gardens, parks, farms, countryside and moors need to become a better network for nature - part of a nationwide network that helps wildlife thrive.

Intensive farming and urban development have contributed massively to the decline of our wildlife in the past 100 years, so the rules that guide farming and planning both have a huge impact on our wildlife. There are also specific risks that need action from Government, for example Local Wildlife Sites are not mentioned at all in the draft Planning Policy guidance.

We have now responded to both the Draft revised National Planning Policy Framework and The future for food, farming and the environment consultations and will provide an update on developments as soon as we know more.

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Consultation overviews
Aerial photo of Woodhouse Washlands Nature Reserve: R.Storrar, SHU

The Future for Farming and the Environment (This consultation closed on Tuesday 8th May)

As the UK moves towards leaving the EU, the country will need to decide how it replaces the payments currently made to land managers and farmers – including how much and for what.

This government consultation is asking exactly those questions. All members of the public, irrespective of whether they are a farmer or just someone who lives in Sheffield or Rotherham with an interest in the natural world, are being encouraged by the Government to respond.

Please take the time to do this – we have provide some suggestions for some of the key questions below, which we hope will help develop a nationwide network for nature’s recovery.

The consultation asks for your views on where current public money, in the form of subsidies to farmers and land managers, will be spent in the future. It will also help to establish how the rules and standards for land management should be set and enforced.

If we are to secure nature’s recovery we need a revolution in the way that we manage our farmland. What works for wildlife can be good for farms, too. Farmers need healthy soils and huge populations of pollinators, like bees, to grow crops. We need clean, healthy water running into our rivers. We need a wildlife-rich countryside to spend time in, and feel happier and healthier as a consequence.

To ensure this, we want to see rules that:

  1. Reward farmers and land managers for the benefits they provide for society, like clean water, healthy soils and a wildlife-rich countryside
  2. Replace the current EU subsidies to farmers (known as the Common Agricultural Policy) with a system that supports public benefits and environmental outcomes for society
  3. Make it easier for farmers to help nature by changing the culture of regulation, including through better use of technology to check that rules are being followed (which would free up more time for delivery)

The government has asked for response to a series of questions in sections of a report called ‘Health and Harmony: the future for food, farming and the environment in a Green Brexit’.

The report and the online consultation link can be found here.

We would suggest that you particularly concentrate on replying to the questions at the end of the following sections in the document:

1. Agricultural transition

2. Public money for public goods.

3. Enhancing our environment

4. Supporting rural communities and remote farming - specifically the first question: How should farming, land management and rural communities continue to be supported to deliver environmental, societal and cultural benefits in the uplands? As this relates to Sheffield’s moorlands.

We are developing our own local response to the consultation whilst also working alongside The Wildlife Trusts nationally.

The key points we will be making, which you are welcome to use in your own response, are:

(1) Reward farmers and land managers for the benefits they provide for society
Farmers and land managers should be paid to provide public goods, public benefits or outcomes:

1. More, bigger and better natural habitats
2. Thriving wildlife everywhere
3. Abundant pollinators
4. Healthy soils
5. Clean water
6. Clean air and climate change mitigation
7. Flood risk management
8. Healthy people (achieved via access)

Currently, the consultation document doesn’t mention habitat maintenance, connectivity, and expansion; without including this, the government’s stated ambitions for nature’s recovery will not be achieved.

Managing land in a way that benefits nature often gives many amazing outcomes at once; a well-managed, wildlife friendly farm with rich, fertile soils will naturally support more wildlife species, store water more readily and for longer, and help mitigate against climate change. Ranking or separating them, as the consultation paper requests, is unhelpful.

The consultation also fails to mention targets for these areas. Without targets, it will not be possible to know how we are performing, where we can improve, or where to target funding. Public payments for land management should be targeted and allocated at a local level through local environment network plans. These use ecological mapping (a spatial approach to identify societal and environmental needs) to help target resources and investment in land management, having the greatest impact and value for money.

The consultation document says little about the advice that will be needed to ensure the success of the scheme. Managing land for wildlife can be complicated, and farmers who have access to expertise do better than those who do not. The government needs to recognise the importance of this specialist advice in caring for the environment.

(2) Transitioning away from the Common Agricultural Policy

The consultation document proposes to phase out Direct Payments. These make up over 80% of payments to farmers and are linked to the area of land that is owned or looked after. The Wildlife Trusts collectively receive considerable sums through Direct Payments, but we believe that it is the right thing to move to a system based on rewarding farmers and land managers for the public benefits and environmental outcomes.

This is not without risk. The government must ensure that the transition dovetails with a new environmental land management system, to ensure that there is no ‘cliff edge’ in terms of environmental protection and land management in the interim.

(3) Changing the culture of regulation

It must be easy for farmers and land managers to help nature, without being weighed down by unnecessary bureaucracy and paperwork. Fewer inspections and the better use of technology to identify whether rules are being met (e.g. through remote sensing) could bring environmental benefits, with more time being freed up for landowners to do what they are best at.

However, there are risks. Currently, to receive direct payments, farmers must comply with certain minimum environmental (and animal health and welfare) rules – called cross compliance.

First, under the new system, the incentive to comply will be reduced because there is no threat of fines and/or a withdrawal of payment. This makes the enforcement of the rules even more important. Secondly, there is a risk that certain laws and rules fall between the cracks, as they are not part of domestic legislation. Boundary features like hedges are one such risk – their maintenance is currently part of cross-compliance, bringing a range of benefits for wildlife through connecting habitats and providing nesting sites.

Construction of flood bank defences at Centenary Riverside: Dan Hoffman

The National Planning Policy Framework (This consultation closed on Thursday 10th May)

The Government has launched a consultation to ask for views on a major overhaul of the rules that guide planning for development: the National Planning Policy Framework. Whether this is one or two houses at the end of the road, a major 5,000 house development, or a motorway service station proposal on an ancient woodland, these rules will shape the future of what development goes where. It sets out the way how different kinds of development should be located, designed and built, and what infrastructure and services are needed. Although the emphasis is on housing, the framework and consultation applies to all forms of development.

About 36 square miles of land are used by new developments every year, so the outcome of this consultation is hugely important for wildlife.

We want to see rules that:

  1. Protect wildlife and secure recognition of Local Wildlife Sites (which lose planning policy protection under the current proposals)
  2. Integrate wildlife habitats into new developments – to benefit wildlife and people
  3. Commit to an improvement for wild species and habitats from all development (‘net biodiversity gain’)
  4. Require that new developments contribute to a national ‘Nature Recovery Network’ by including this in local planning strategies.

The draft text for the framework and the consultation proposals (which include the consultation questions) link can be found here. 

We are developing our own local response to the consultation whilst also working alongside The Wildlife Trusts nationally.

The key points we will be making, which you are welcome to use in your own response, are:

There are many elements for which we would like to express support, and several that concern us and for which we will request changes. We are looking to secure the implementation of a Nature Recovery Network. Sitting as part of an Environment Act (that requires the establishment of an ecologically coherent network following the principles set out by Sir John Lawton’s Making Space for Nature), we need policy that will:

A. Protect the existing elements of a potential network of protected wildlife sites, like nature reserves

B. Require local authorities to provide a spatial plan for the network, linking up current wildlife-rich areas through planning that allows wildlife to move and flourish

C. Require development to contribute to the establishment of the network, by actively creating spaces for nature in all new developments

The review of the NPPF is an opportunity to ensure that development contributes to the establishment of a Nature Recovery Network but hasn’t strengthened the relevant policies enough.

1. A key issue is the lack of any protection for those undesignated sites that already make up part of the potential network. We are lobbying strongly for Local Wildlife Sites (formerly known as Sites of Nature Conservation Interest) to be included in the hierarchy of protection.

2. Positive spatial planning for the environment not only makes it easier to locate development in a way that avoids damage to existing sites but can make the most of the benefits that nature provides to communities (ecosystem services) and enable development to help strengthen these services. There needs to be a requirement that local strategic plans, as a minimum, work with neighbouring planning authorities to provide this.

3. We welcome the policy support for net gain, but there is a lack of clarity and consistency in the current draft of the revised NPPF on net biodiversity gain had how this links to a Nature Recovery Network. The contribution needs to be a requirement, not an option.

You can compare the current framework and new draft version side by side in order to see the relevant changes by going to: https://draftable.com/compare/gScyBhZoTtUa

Pictures: Top photo of a Swift: Stefan Johansson, aerial view of Woodhouse Washlands Nature Reserve: R.Storrar SHU, flood defence bank construction at Centenary Riverside Nature Reserve: Dan Hoffman.

Updated 17th May 2018