Act Swiftly - urgent call to action

These consultations have now closed - thank you to everyone who took the time to respond.

Read the Sussex Wildlife Trust's response to the Planning consultation

Briefing: Local Wildlife Sites in the National Planning Policy Framework

The Wildlife Trusts' response to Defra's Health & Harmony (farming policy) consultation

Summary - The Wildlife Trusts' response to Defra's Health & Harmony (farming policy) consultation


Why is this important?

This is a rare and unique opportunity to influence new national planning and farming policies to reverse the decline of wildlife in our county and support nature's recovery.

  • Thousands of new houses are planned for Sussex in the next five years
  • At least 65% of our Sussex landscape is farmed
  • Precious wild places and the species that depend on them have suffered catastrophic declines over the past 70 years – intensive farming and urbanisation have been major causes
  • The government needs to know that people care about these issues

Who should respond?

Nature-friendly farmers, planners, local authorities, wildlife experts and people who care about nature - your views are important.

How can I submit my views?

*The consultations have now closed*

1) Respond to the government consultation on the revised National Planning Policy Framework by: he consultations have now closed

2) Respond to the government consultation on the future of national farming policy by:

Agriculture Consultation Team
1b - Future Farming Directorate
Department for Environment, Food and Rural Affairs Nobel House
17 Smith Square
London
SW1P 3JR

3) Tell your friends and family and encourage them to get involved and respond too.

Fully completed online surveys will always carry the most weight but you don't have to answer every question. If you'd prefer to set out your thoughts in a letter then you can send them by email or by post. Your views are important - every response is noted.

What are the key concerns?

Planning

Consultation on the draft revised National Planning Policy Framework
Deadline: 10 May
Click here to fill in the online survey

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

Please feel free to use any of these points in your own consultation response:

Q2 – Local Wildlife Sites need to be included in the list of things which provide a specific reason for restricting development. They're one of the last refuges for wildlife and are hugely important for people and wildlife and need protection under the planning system.

Q6 – This consultation is lacking important strategic policies on conservation and that the enhancement of the natural environment needs to be ‘spatially planned’

Q20 – There isn't any reference to the importance of local access to nature in promoting healthy communities; people need nature to feel happier and healthier and this is a right that everyone should have

Q35 –
• The government has included a requirement for policies and decisions to provide net gain for biodiversity – more wildlife after the development than before. Stronger wording would require Local Authorities to map a Nature Recovery Network
• There is a recommendation that existing sites designated for biodiversity, wildlife corridors and stepping stones should be mapped - this is a great opportunity!
• Local Wildlife Sites need to be specifically included in the sites that should be identified and mapped as components of local wildlife-rich habitats
• It is suggested that only sites for habitat restoration or creation that are identified by local partnerships should be added to this map - this can be challenged. This is because local partnerships may not exist in all areas, not have sufficient resources to do this work, which should be carried out by the local authority.

We need policy that will:

  1. Protect the existing elements of a potential network of protected wildlife sites, like nature reserves
  2. 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
  3. Require development to contribute to the establishment of the network, by actively creating spaces for nature in all new developments

The review of the National Planning Policy Framework (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.

Farming

The future for food, farming and the environment in a Green Brexit
Deadline: 8 May
Click here to fill in the online survey

This government consultation will help drive the decision on where public money, in the form of payments 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.

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 Common Agricultural Policy with a system that supports public benefits and environmental outcomes for society
  3. Make it easier for farmers to help nature through changing the culture of regulation

Please feel free to use any of these points in your own consultation response:

1. Farmers and land managers should be paid for providing:

  • More, bigger and better natural habitats
  • Thriving wildlife everywhere
  • Abundant pollinators
  • Healthy soils
  • Clean water
  • Clean air and climate change mitigation
  • Flood risk management

Currently, the consultation doesn’t mention habitat management, 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 the benefits, 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 need 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 public benefits and environmental outcomes. This transition must dovetail 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 should 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.

Under the proposed new system, the incentive to comply will be reduced because there is no threat of a fine and/or a withdrawal of payment. This makes the enforcement of the rules even more important. There is also a risk that certain laws and rules (e.g. regarding hedgerow maintenance) will fall between the cracks, as they are not part of domestic legislation.

Let's all shape UK policy to help wildlife thrive again in the 21st Century