BASC has submitted an in-depth response to a consultation launched by Natural England (NE) which proposes a change on how it reports the performance of England’s most important nationally protected sites – Sites of Special Scientific Interest (SSSI).
The change could lead to issues with consenting – something that many shoots and wildfowling clubs on SSSIs require to undertake their activities.
The first thing to know is that most SSSIs are comprised of smaller areas called units. The enormous Wash SSSI in Norfolk for example is made up of 60 units. The smallest SSSI is in fact just one unit – it is a seven-metre square roof space in a loft that lesser horseshoe bats roost in!
Another thing to know is that a SSSI can have one or more features of interest that NE and the incumbent landowner must ensure is in favourable condition.
Currently the reporting structure tells you how many SSSI units are in what condition. Natural England’s proposal is to change the reporting process to include the features instead of the units.
NE’s consultation set out several ways to report SSSI feature performance. Their favoured route is that of giving the ‘least favourable’ score.
So, let us say a SSSI is designated for bittern and otter. Now otters have made an amazing comeback throughout the UK and so let us assume on our SSSI that all the units are favourable for otter. So, the SSSI gets favourable for the otter feature in the report.
However, for bittern it is a mixed picture across the SSSI’s units, while the majority are in favourable condition, one scored unfavourable declining. The least favourable approach, favoured by NE, means the bittern feature would be scored unfavourable declining across the whole SSSI.
So what? Especially as this approach is one used in Scotland and Wales.
Natural England’s least favoured prioritisation would lead to a substantial downgrading on the performance of the SSSI network. NE admit that the favourable and unfavourable but recovering conditions will drop from 91.9 per cent to 54.4 per cent.
In response to the proposal, BASC has requested assurances that the downgrading of the majority of SSSIs will not have a knock-on effect on consenting of shooting.
BASC uses the statistics as a benchmark for government performance, but more importantly for use in consenting applications for shooting over designated sites such as Special Protection Areas, Special Areas of Conservation and SSSIs. Any application will rightfully consider the condition of the designated sites and we know from experience the overall condition of a site influences the outcomes of consenting applications.
It is extremely important that consenting decisions are not unduly influenced by this reporting change and in our consultation response we asked for just that confirmation from NE. This proposal will lead to an overnight condition change of species and habitat features, yet their general health will not have changed, for that reason decisions on consent applications should not need to be impeded.
In addition, BASC has long felt disadvantaged that consenting decisions have been made on data that is either incomplete, out of date or both. In our response we highlight that on the Wash SSSI, only one of the 60 units is classed as being of unfavourable declining condition, and this was last assessed 12 years ago. NE’s least favourable proposal will see the whole Wash given an unfavourable declining condition rating on an out-of-date assessment.
NE has acknowledged the need to invest in reducing the unknown unit conditions, but it also needs to improve the regularity of unit assessment. Especially as this is impacting opportunity.
Therefore, our response pushes NE to commit to reviewing the condition of every SSSI every five years or attributing a score of condition assessment overdue. This would put very real pressure on government to properly resource condition assessments as SSSI feature reporting would start to flag up the number of sites where assessments are lacking.
NE is almost certain to go with its proposed approach but what really matters is the quality of data informing the condition scores and how NE uses it in real world decision-making. As ever, the devil is in the detail.