Guest blog – Conservation 21 by Ian Carter

Ian Carter has worked as an ornithologist for more than 25 years. He was involved with the Red Kite reintroduction programme in England and has a keen interest in the conservation of raptors, bird reintroductions and wildlife management more generally. He is particularly interested in human attitudes towards wildlife and the complex ways in which they interact with science.


Conservation 21: Natural England’s Conservation Strategy for the 21st Century – by Ian Carter

I wrote something in the November issue of British Birds about the seemingly endless stream of conservation strategies and prioritisation exercises to which we are all subjected these days. I thought it might be interesting here to look, more closely, at one example.

I doubt it is intended to last for the whole of the 21st century. But, for the short term at least, this is what Natural England staff are now working with when trying to justify the work they do on the ground. If you take out the pictures it’s a little over five pages long so it’s easy enough to read through the full version.

It contains plenty of words that everyone involved in conservation could hardly fail but to agree with, under three ‘guiding principles’: Creating resilient landscapes and seas; People at the heart of the environment; Growing natural capital.

But the document also contains some rather more troubling statements. They all come under the banner of the ‘outcomes approach’ and this is what makes the strategy very different from others that have gone before it. It is made very clear that what is being outlined reflects a major change in the way the organisation should be working. It is essentially about giving people who want to undertake activities that will impact on wildlife more of what they want, more of the time. The ‘outcomes approach’ is defined in the strategy as ‘delivering better long-term outcomes for the environment by understanding people’s interests and needs, and working towards a shared vision.’  The ‘better outcomes’ bit might sound quite hopeful but consider some of the detail within the text. To keep this short I’ve picked out just three examples but there are plenty more along similar lines:

‘We need to work with people and stakeholders to explore the best options to achieve resilient and healthy landscapes and seas. There will always be a range of perspectives and options, our aim should be to find the best one, not define the right one’

You might think that the ‘best one’ and the ‘right one’ would be the same thing, but apparently not. The ‘right one’, which is not the aspiration remember, is presumably supposed to be the option with the best possible outcome for wildlife, with wildlife conservation as the primary perspective. The ‘best one’ must mean the least damaging solution that everybody can live with – the one that takes full account of the full ‘range of perspectives and options’, including those of landowners and developers. Perhaps there is another way to interpret this rather odd form of words but, if there is, it’s not clear to me.

‘….our ambition for securing environmental enhancement will move at a pace that endeavours to bring people with us through sustainable, long-term solutions, rather than imposing prescriptions to meet arbitrary delivery timelines.’

This, surely, is code for proceeding more carefully and more slowly when trying to persuade people to meet their environmental obligations, in order to try not to upset them too much. ‘At a pace’ could, of course, be an aspiration to ‘go a bit faster’, but read the rest of the sentence; the references to the ‘long-term’ and a promise not to impose ‘arbitrary timelines’ make the true meaning clear enough.

‘We need to understand how to align statutory conservation ambitions with the wider objectives of the people we depend on to achieve them in any given place. We need to become more fluent in other people’s language.’

The statutory parts of Natural England’s remit are the things it is obliged to do under the legislation. Even here, there is apparently scope for compromise. It is cunningly worded but try replacing ‘align’ with ‘water down’. And if you think substituting words is taking a bit of a liberty, consider what else ‘align’ could possibly mean given the words that follow it; fluency in the language of ‘other people’ is hardly going to lead to a strengthening of ambitions for wildlife.

You can already see examples of this changed approach on the ground, perhaps most egregiously from an ornithological perspective in the Bowland Fells SPA. Here, conservation ambitions have been sufficiently ‘realigned’ to allow the culling of the species for which the site has been designated. Fluency in the language of others has been closely allied to illiteracy in the language of nature conservation. We can expect more along similar lines in future, not least because the Bowland case has been used within Natural England as a shining example of how this new approach should work.

As others have pointed out, Natural England remains an organisation with many staff (including some senior managers) who are doing all they can to achieve gains for wildlife, despite what is written in this strategy. And whilst I’m far from convinced, maybe there will be occasions when trying to placate landowners or developers does produce the hoped-for benefits for wildlife in the longer term. If so, it would be good to see some examples. Judgements should be made on a case by case basis but if you can find ten minutes to read Conservation 21 you probably won’t come away with too much optimism for the future.


16 Replies to “Guest blog – Conservation 21 by Ian Carter”

  1. it is a not very subtle complete change in many ways and if the Bowland Gull cull is one of the “outcomes ” of this approach it is frankly scandalous.
    To my mind NE has the following purposes in life to give Gov’t independent advice on wildlife and conservation issues ( we know that DEFRA has made sure that is no longer the case)
    To protect our designated sites and continually up date that information such that other sites may be designated and make sure that landowners are complying with those designations, no ifs buts or maybes. Essentially to be the champion of wildlife and conservation within government.
    This outcomes approach waters this down and indeed in some cases completely negates all of those.It means for many of us who believed those thingsthat NE really is by its own admission no longer fit for purpose. Is it why you left Ian?

    1. Paul – Yes I think the Bowland case probably was the point I decided to leave. I’m not keen on saying any organisation is ‘not fit for purpose’ partly because the expression is so hard to pin down – it depends on how you define the purpose for one thing (though it is ironic that this management speak has found its way into common usage to criticise the type of people that invented it!). Also because NE contains so many people who are still battling for wildlife and sometimes succeeding to achieve gains (or minimise losses) against considerable odds. Where that happens it deserves recognition so I think its best to judge things case by case.

      1. Don’t get me wrong Ian I know there are people still there who are trying to do their very best for our wildlife. Yet the big decisions are probably made by folk of higher grade that believe in “positive outcomes for customers” and sadly those customers are not our wildlife “As witnessed by the Lesser Black-backed Gulls of Bowland.”

    2. we have colour ring proof that Bowland lbbg gulls spend non-br time here in The Gambia where they are protected ! pity you are killing them up there – I wrote to all the UK players & did not enjoy the common grace of a reply – bws Clive

  2. There is many situations in our management that need addressing but look at only one – The massive decline of dung beetles. We are on the verge of having no dung beetles left due to chemicals in stock. Horse fields have to have their dung removed by hand. Dogs have to have their dung placed in plastic bags.

    There was a time when every dog poo had a beetle drop down to bury the mess. This was so obvious that a London council even thought of bringing the beetles to the streets of London [not just Abbey Road!] but of course they would have problems burying the poo in the concrete and tarmac!

    We are seeing other species decline due to this loss of food like Little Owls, Red backed Shrikes, Black Grouse and many more. I once took my farmer’s cow muck into a bag in the 1980s and let it brake down only to find it alive with beetle lava.

    Ivermectin was found in only 1975 and the many facts are still not known about its effects in humans but still it widely used around the world to kill parasites and is active 147 days after it has come out of the animal or person. It is the main killer of most insects and when it is claimed that 80% of all food of breeding waders is from dung feeding insects you would suspect some organisations would be shouting but instead ‘Kill Foxes and Crows if you want a healthy wader population’.

  3. I wish I could disagree with you, Ian, but your reading of the of the text seems to be correct. In my view this is outrageous. I think we all understand that there are competing pressures on the landscape and that the government – local and central, have to find ways to balance the various interests but the role of Natural England should be unequivocally to protect the interests of wildlife. Of course NE wont win every battle but if it starts from the position outlined in this strategy nature will lose every battle. Natural England was not supposed to be a development agency – it should be nature’s advocate in the decision making processes that determine how our landscape is developed and used. It should make the case for the protection of wildlife that is threatened by any given proposal or activity without fear or favour and based objectively on the facts at its disposal, not on the basis of some politically or commercially desired ‘outcome’. Sadly, what NE ought to be and what the government has turned it into are poles apart.

  4. Well done to Natural England for creating the new oxymoron of ‘statutory ambition’. I shall now set out on car journeys with the statutory ambition of staying within the speed limit, hopefully for other road users, with more success than my ambition to learn Spanish.

  5. This sentence from the summary, on the page linked to above, says it all.
    “The government’s ambition is for England to be a great place to live, with a healthy natural environment on land and at sea that benefits people and the economy.”
    In effect, the environment is there to be exploited by people for economic gain.

    The document itself states: “Conservation processes and practices, conceived to protect
    the environment, often no longer represent the most effective means of achieving real and lasting environmental outcomes.” It goes on to talk about needing “a more useful way of looking at our relationship with nature.” Useful for whom?

    It also talks about NE listening more. Ok, here’s a simple message: “You’re not fit for purpose.”

  6. Smoke, mirrors and paradoxical ‘verbage’ – English Hen Harriers, forget your fancy sky dancing and get fluent in this language of high-end management-speak; those ‘arbitrary delivery timelines’ are evading you. Conservation 21? Catchservation-22 more like.

  7. It is amazing how many people have left government bodies since 2010, NE, EA, FC etc etc. A real skills drain. Can’t think why it’s happening…

  8. Ian’s analysis is spot on – there is no reason to suspect anything other than the worst in the present political climate, and NE’s carefully thought through words look particularly ominous in the shadow of the (actually badly needed) increase in house building finally recognised by a Tory party slowly waking up to what it has done.

    There is a solution. Michael Gove has in front of him the Natural Capital Committees recommendation for 250,000 hectares of ‘community forest’ around our towns and cities. It may not be what NE means, but it meets all their aspirations – you only have to look at housebuilders adverts for developments around London to realise that they have recognised people’s ambitions for a very different lifestyle where green space is central.

    So why aren’t we hearing about this economically hard-headed proposal from the conservation NGOs ? Probably because the scale is so big, the ‘community forest’ brings images of swathes of conifers (in fact, think New Forest rather than Kielder) and it isn’t the way conservation operates – read current strategies and they are all about ‘demands’ on Government, and the assumption Government must have all the bright, new ideas (which clearly it doesn’t).

    The NCC proposal is quite different – it provides the solution to a huge problem – how to build more houses without a massive public backlash. It has an estimated economic value of + £500 m per annum (unlike most conservation ‘demands’ which always cost) and within that scale there is massive space for biodiversity – if we simply relaxed management on that area of land we’d see huge gains, but within the optimum solution there is potential for massive gains – how does maybe 10,000 ha of new reedbed, primarily perhaps for cleaning grey water, look for starters ?

    And in Michael Gove’s go-it-alone Britain it could be a globally unique selling point for Britain as an attractive place to live and do business.

  9. Here is a locally well-known example of the emasculation of Natural England.

    I tried (and failed) to protect a rare colony of bats against a railway development. All I wanted was the current train speed to be maintained through a tunnel being used as an important fly-through (commuting route), roost and hibernaculum for up to 13 species of bat.

    At the first Public Inquiry, Natural England supported maintaining the existing speed limit, and refused a license for the work.

    The outgoing Labour Government – and then the in-coming Coalition Government – forced Natural England to change their position, and the Public Inquiry was ‘re-convened’ (using the ‘keep having Public Inquiries until they get the ‘right’ answer’ method).

    The Government used the Hampton Principles of Regulation written into Natural England’s statutes by the Labour Government (2005).

    At the subsequent, second, Public Inquiry, Natural England changed sides and became a supporter of the railway development.

    Since I was an objector, I had the right to cross-examine the Natural England representative at the Public Inquiry…

    Under my cross-examination this supposed ‘expert opinion’ did not know (a) how many bat species there were in the UK, (b) did not know the principle avian predators of bats, and, therefore, (c) did not know the level flight speed of the principle avian predators of bats.

    He also said that ‘it didn’t matter in the great scheme of things’ if the colony died out as a consequence of increasing the train speed limit.

    I was trying to establish the scientific reason why the existing 30 mph speed limit was able to allow bats to successfully use this tunnel for decades. At such a speed bats had already evolved to co-exist with their avian predators. The railway development intended to increase the speed limit to 75 mph (against which bats would have no defence).

    I pointed out that maintaining the 30 mph speed limit (Natural England had originally suggested keeping a limit of 40 mph) would add just 46 seconds, at most, to the proposed journey time from Oxford to London.

    I think Natural England deliberately sent along a complete ‘duffer’ to the Inquiry (the Head of Land Acquisitions – who had a degree in Geography) because anyone seriously concerned about bats would have been able to tell the Inspector that a 75 mph speed limit would soon threaten the colony through endless collisions and barotrauma.

    Natural England’s ‘best option’, therefore, was to install lighting in the tunnel – triggered by on-coming trains – which would drive light-phobic bats away from the tunnel and railway cutting, while the fast trains would speed through. And then the lights would extinguish.

    However, after many experiments, the very best results they could achieve was a 60% response to the lighting. 40% of the bats, either in the tunnel or railway cutting at the time, failed to change their behaviour.

    I asked the Natural England representative what he thought would happen to the 40% of the bats in the environs of the tunnel which did not respond at every train pass. He didn’t know, but reiterated that it didn’t matter.

    As it was, the Inspector said he had to take Natural England’s written submission, as the statutory body charged with officially advising Government, that increasing the speed limit, with the lighting mitigation, would be OK for the colony, and ignored my protests.

    Because of Natural England’s change of policy, neither the Bat Conservation Trust nor BBOWT would support me at the Inquiry, through fear of losing funding:-(

    Some others in attendance asked whether the results of the subsequent monitoring of the bat colony’s health (after train services resumed at 75 mph) would be published?

    We wanted to know whether Natural England’s written submission that the increased train speeds, with lighting mitigation, would not seriously adversely effect this colony, or the local bat populations, would be proved correct or not.

    (Bare in mind that the railway developers also felled up to one thousand mature trees in the vicinity of this tunnel, destroying the bats’ vegetation corridor and guide.)

    We were informed that any such monitoring would be classified as “commercial in confidence”, and that any publication of the fate of this bat colony would depend entirely on the railway company’s wishes!

    I asked whether Natural England would re-introduce the 30 mph speed limit if the monitoring showed that the colony was in serious decline. The representative said No.

    Natural England were happy to leave this colony of 13 species of bat to its fate, regardless.

    The Natural England representative said that they had to bear in mind the economic consequences of maintaining the lower speed limit.

    Following this, we all received individual letters from Network Rail reminding us that should we put one foot on railway land (for any purpose, such as the monitoring of bats or the photographing of any dead ones) we would be fined up to £1000.

    I protested to the EU Commission that this decision breached the Habitats Directive, but after two years consideration, was REFUSED LEAVE to take the case to the Court of Justice.

    Stitched up.

    1. Of course, choosing to save 46 seconds of scheduling rather than a mere 13 species of bat is a no brainer.
      Anyway why go to court over stupid time wasters? Bats, if they can’t be bothered to become fluent in the language any other stakeholders, why should Natural England take the trouble to represent them?

      Keith, thanks for your heroic efforts …. Will we ever know what happens to them?

      1. Thanks Murray…

        It is difficult to foresee what might happen. The environment has been more-or-less destroyed: trees and shrubs removed (a barren landscape) and faster trains.

        Natural England forced the replanting of some fifty or so maidens and whips: they will take donkey’s years to grow to any size (around 1000 mature oak, sycamore, ash, rowan and crataegus had been removed).

        The replanting is on just six inches of soil! Network Rail removed 15 feet of Oxfordshire clay, and replaced it with fist-sized rocks, then gravel to top it (all held back, in a cutting, by pre-cast concrete blocks) I cannot see even crataegus growing to any size on such a thin soil.

        Where new maidens and whips were not planted, the six inches of top soil were seeded with a standard wild-flower mix. But there is no management – it will surely eventually turn rank.

        And the great sop to the lost roosting and hibernating crevasses in what had been an old Victorian rail tunnel (now filled with pressurised cement grout!) Natural England installed twenty, exposed bat boxes on poles (there being no mature trees left).

        Then the new rail service started last December. But this is just Phase 1 of the Chancellor’s Budget ‘boost’ for the East West Rail route (Oxford – Cambridge). The speed and frequency of trains increased from 30 per day at 30 mph, to just less than 100 per day at 75 mph. In Phase 2, the frequency of trains will increase to around 200 per day.

        The upgrade and the route is required to service Arup’s Infrastructure Maintenance Depot at Calvert (north east of Bicester) for the construction of HS2. So the numbers of trains will increase still further.

        I have seen what I take to be pipistrelles this Autumn. If I can sort myself out, I was interested in the smart phone device for identifying calls…

        We have already had the local foxes and badgers cut to pieces on the rails by the faster trains: I used to get up to three badgers (simultaneously) and who knows how many foxes feeding below my bird feeders (my bedroom backs onto the rail cutting). Plus row deer and muntjac. There are no badgers, foxes or deer now.

        My birds numbers (other than Jackdaws and Collared Doves) have collapsed to next to nothing… The House Sparrow population simply disappeared. I still get Starlings, but I have previously recorded Tree Creepers, Bramblings and Reed Buntings! Not to mention Sparrow Hawks and Great Spots..

        A great slow worm concentration was simply wiped out.

        Someone is supposed to monitor the bats, but it was decided that the results would be kept confidential to Network Rail. They are hardly likely to publish bad news. They sought, and were granted, permission to end the lighting ‘mitigation’ if the bat population disappeared! They were very keen to get that ruling!

        They knew full well what would happen – as did Natural England.

        All for 46 seconds.

        It is even more inexplicable, since the tunnel is between, and close to, Oxford Station and the new Water Eaton Parkway Station. The passenger trains have to stop at both. And who cares about saving time on overnight freight?

        What is more galling is that the old passenger service was limited to 30 mph along the entire line to Bicester! The upgrade allows speeds up to 110 mph elsewhere – and 75 mph through the tunnel. So there was a H U G E reduction in journey time over the previous timetable.

        Yet Network Rail (and Deutsche Bahn – who own the track operator) claimed at the Public Inquiry that the passenger service would be ‘unviable’ if it wasn’t *another* 46 seconds shorter!


  10. Natural England Bylaw Making Powers Consultation June – August 2018

    If Conservation 21 is about ‘economic growth’ funding Natural England’s statutory duty – then this damaging concept is about increased multi user access and ribbon development in the Community.

    Economic growth through increased public interest is a strategy which has targeted getting European otters into British ponds in every County, a strategy assisted by the Environment Agency.

    This will create the mass public interest and multi user collaboration who now demand access, as they all want to be pond dippers!

    Greater access to SSSI sites will create a toxic ‘fall out’ cloud of wildlife misery.

    Green moss will give way to muddy footfall, graffiti and plastic – all a result of greater access which will destroy these SSSI’s sites.

    …And who picks up the bill for Natural England’s (Andrew Sells) negligence – the private landowners who host SSSI sites! There are 4,119 sites in England. 40 percent of which, are on private rural land, many just small agricultural concerns or residential homes.

    These are the people who pick up their litter, take down the poo bag trees, mend the fences, are frontline to ‘policeing’ difficult members of the public, have to cope with security concerns, fear to leave their home unattended and very, very out of pocket, – their property devalued and unsaleable.

    This is surely far from being the ‘best’ option.

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