Written Evidence submitted by The Wildlife Trusts (PLD0017)

The Wildlife Trusts protects, champions and acts for wildlife and wild places on land and at sea. We believe that people are part of nature; everything we value ultimately comes from it and everything we do has an impact on it. Our natural environment is under strain. Degraded and poorly managed peatlands are just one example. Wildlife Trusts are working across the country to restore and maintain our peatlands as the foundation of long-term carbon storage.

But we need more than this. We need a strong Environment Bill which includes provisions to ensure a long-term strategic approach to environmental planning so that the right action can be delivered in the right place; and that this should be done through, but not limited to, the creation of a Nature Recovery Network: a network that extends beyond existing protected sites and drives improved ecological functioning and ecosystem restoration across England.

The Wildlife Trusts are a movement of more than 800,000 members, 40,000 volunteers, 2000 staff and 600 trustees, from a wide range of backgrounds and all walks of life. We manage over 2,300 nature reserves for the benefit of wildlife and people. We manage almost 100,000 hectares of land and give advice to more than 5,000 landowners each year.

1.                   What is the current state of peatlands in England, and how is it changing?

1.1 Extent of peatlands

The IUCN’s extensive 2011 assessment of UK peatlands[1] showed that there are 23,000 km2 of peatland habitat, covering ~9.5% of the UK. The majority is found in Scotland, with England supporting only a tenth of the total. Furthermore, there have been dramatic losses – peaty soils make up a third of all UK soils, and bog & fen habitats will typically have existed on deeper peats (>40cm) but have been lost from nearly 10,000 km2 of these across the UK.

This significant loss is largely attributed to conversion to forestry, cropland, or agricultural grassland, and has been seen across upland bogs, lowland bogs and fen habitats. Since c.1850, the area of lowland raised bog in the UK fell by 94% from 950 km2 to 60 km2. In England, the loss was 98.6%, leaving only 5 km2, and in the prior stronghold of the north-west, a 99% loss means less than 1 km2 remains[2]. Losses continue; Lincolnshire’s lowland fens are expected to have almost disappeared in the next 10-20 years.

In 2017, CEH updated some of this work: Evans et al[3] reported that in England, the total area of mapped peat was 6,822 km2, of which only 19.8% supported near-natural or re-wetted bog or fen, whilst 80.2% was under forest (9.6%), cropland (26.8%), grassland (11.1%) or modified bog (32.8%, including via extraction). 

1.2 Condition of Peatlands

The maintenance of peatlands relies on water; when drained or drying, peatlands waste away through oxidation, reducing in depth & extent and releasing CO2 to the environment. These damaged or ‘wasting’ peatlands are extensive.

The Yorkshire Peat Partnership (YPP, led by Yorkshire Wildlife Trust) coordinates the restoration of badly-degraded peatlands in the uplands of northern Yorkshire. Since 2009 YPP have surveyed 53,000ha using field observations, aerial photography analysis and drone footage. Using this survey information and extrapolating to the whole area of blanket bog in Yorkshire, it estimates extensive damage, caused by:

• 577ha of bare un-vegetated peat, micro-erosion and dendritic erosion
• >2750km of erosion gullies
• 2475km of eroding exposed peat hags
• 7500km of artificial drainage of which 4900km are actively eroding

Eroding peatland surfaces yield significant sediment losses - representing particulate carbon which is additional to that lost through gaseous emissions. To preserve this carbon store, Shuttleworth et al, 2015[4] demonstrate that restoration work (particularly revegetation of gullies and gully floors) can reduce the physical loss of sediment from peatlands by two orders of magnitude.

Drying, erosion or other changes also result in the loss of peat-forming vegetation[5]. Most UK peatlands are no longer peat-forming – in 2010 Littlewood et al[6] calculated that 16% are severely eroded, 10% have been afforested, 11% are affected by past peat cutting and 40% have been modified or destroyed by conversion to agriculture. This inability to form peat in over three quarters of peatlands means that losses through oxidation and erosion are not offset. Restoration is needed to reverse this.

Data collected by YPP reveals that the vegetation present on North Yorkshire’s blanket bogs is indicative of dry or drying bogs[7], and around half of the survey points show evidence of burning (a high proportion given the presumption against burning set out in the Heather and Grass Burning Code). This lowers the water table and further degrades vegetation communities, preventing peat formation and limiting the habitats’ ability to resist or recover from environmental change. 

2.                   What is the potential contribution of peatland restoration to the UK’s net zero greenhouse gas target, and the consequence of inaction?

In considering the ability of peatlands and peatland restoration to contribute to net-zero targets, both the current annual uptake or release, and the potential release of stored carbon, must be considered.

Evans et al (2017)[8] concluded that:

• Due to their degradation, UK peatlands as a whole act as a significant net source of Greenhouse gasses, contributing 23,000 kt CO2e yr-1, whilst bog and fen habitats in near-natural condition (which absorb CO2, although release methane) are close to carbon-neutral.
• In a modified peatland, emissions only marginally exceed uptake, but the great extent of modified peatlands makes them significant contributors to overall UK peatland GHG emissions (~3,400 kt CO2e yr-1, or 15%).
• Arable cropland occupies just 7% of the UK’s peat, but has the highest GHG emissions per-unit-area of any land-use, emitting ~7,600 kt CO2e yr-1, (32% of UK peat emissions).
• Peatlands converted to grassland occupy a further 8% of the UK’s peat, and emit ~6,300 kt CO2e yr-1, (27% of UK peat emissions). Drained intensive grasslands in lowland areas are the primary source of these emissions.
• Peat under forestry in the UK could be emitting ~4,600 kt CO2e yr-1 (20%), but uptake by tree biomass may offset this.

Uncertainty remains around these figures, which are often based on a small number of scientific studies and would benefit from further research, however they suggest that inaction will see the ongoing release of 23,000 kt CO2e yr-1 at a minimum.

More critical however is the potential further release of stored carbon that will result from ongoing degradation. Despite covering only 3% of the global land surface, peat habitats store 30% of all soil carbon. The authors state that if all of the carbon held in peatlands globally were oxidised, it would raise atmospheric CO2 concentrations by approximately 75%, with catastrophic consequences for global climate. The UK is among the top twenty countries globally in terms of total peat cover, making peatland restoration important for UK targets, but also in terms of global responsibilities.

Peatland restoration offers the opportunity to reduce emissions to near zero from a given site, or potentially to a net sink, and also to prevent the release of locked-up carbon. Future emissions projections to 2050 suggest that currently-legislated peat restoration measures alone (phasing out of peat extraction in England) will have limited impact on emissions, whilst current levels of ambition on peat restoration in all four countries could deliver over 4,000 kt CO2e yr-1 of emissions reductions by 2050. Furthermore, large-scale cessation of drainage-based agriculture on lowland peat offers the opportunity to eliminate the 60% of all current peatland emissions that arable and grassland agriculture on peat soils currently contribute.

3.                   What are the other economic, ecological and cultural benefits of restoring and maintaining peatlands?

3.1 Flood risk management

There is increasing evidence that the restoration of upland peatlands can reduce the impacts of flooding downstream. Shuttleworth et al (2019)[9] showed that revegetation of bare peatland surfaces significantly increased lag times by 106% and reduced peak flows by 27% as a result of increased surface roughness. Gully-blocking further increased lag times by 94% and reduced peak flows by 24%, benefitting downstream communities through reduced flood peaks and increased warning / preparation times. The Moors for the Future project further demonstrates the flood mitigation potential of peatlands[10]. Water retention is equally valuable under low-flow conditions, maintaining higher water tables, supporting baseflows and providing potential resilience to droughts and wildfires. This contributes to the sustainability of water supplies for both public supply, and agricultural irrigation.

3.2 Drinking water quality

70% of UK drinking water comes from upland sources, many of which are in peat-dominated catchments. Removal of Dissolved Organic Carbon (DOC) is a key treatment process for the supply of drinkable water from peat-dominated catchments and represents the largest cost to UK water utilities. There is evidence that peatland vegetation influences the generation of DOC with the highest concentrations coming from heather-dominated plots and the lowest from plots with high cover of Sphagnum spp. (Armstrong et al., 2012)[11]. Restoration of peatlands to conditions with plentiful Sphagnum cover should therefore reduce the costs of drinking water treatment.

Further treatment costs are associated with the removal of peat particles, acidification and heavy metals that may be flushed in by water from degraded peatlands. Moors for the Future describes how removing peat particles from the water from one catchment can cost a water company £2,000-4,000 each week.[12] Sediment eroding from upland peatlands also threatens water supply through infilling of reservoirs, which water companies will typically remove to landfill.

3.3 Biodiversity

Peatlands are home to rare and endangered species that are found nowhere else, and that have been lost from significant parts of their previous range due to peatland degradation. Lancashire Wildlife Trust is working to bring back species missing from their former range due to historic destruction of their habitat, including the Manchester Argus (Large Heath butterfly), bog bush cricket, white-faced darter dragonfly and plants like white beak-sedge, bog asphodel and lesser bladderwort. 

Wetlands including peatlands make up an important part of a connected, living landscape and will form a key component of a Nature Recovery Network (NRN)[13], needed to allow species to move throughout the landscape, respond to change, and to thrive.

3.4 Recreation and Culture

Peatlands have cultural significance in the areas in which they are prominent, influencing place names, and inspiring artists, playwrights and even engineers. Treasured by local people and visitors, they provide opportunity for recreation as blue-green infrastructure and are easily accessible from parts of the country with large populations, like Greater Manchester. In these areas they are an important part of the visitor economy, offering opportunities to support new or existing SMEs.

Lancashire Wildlife Trust’s Chat Moss project[14] worked to engage local communities with the mosslands, finding that they were valued for multiple reasons: “social and industrial history… beauty, amenity, ecological value… a community resource… important in mitigating the impacts of climate change… to help with carbon… the lungs of Salford… important for health and well-being”.

4.                   What are the costs of peatland restoration, and what wider societal and economic adaptations might it require?

We believe that the following points should be considered when looking at the future financing and design of schemes to deliver peatland restoration:

A coherent, spatially mapped network: The Wildlife Trusts believe that a spatially mapped and locally-developed NRN would play an important role in determining which of a range of potential uses for any given piece of land would deliver the most for nature’s recovery[15]. This approach would then favour the delivery of that option over others – it could inform the allocation of funding to reward the provision of public goods, and guide the provision of management advice, to encourage landowners to implement the forms of land management that would provide the best biodiversity and wider ecosystem service outcomes from any given piece of land.

Long term contracts with capital and management funding: Effective and sustained peatland restoration requires both capital expenditure (particularly during the initial years, where costs can be significant) and ongoing management input. The experiences of Yorkshire Wildlife Trust, involved in substantial restoration work, suggest that programmes of at least ten years, and ideally twenty, are required to turn around the levels of degradation that affect upland peatland environments. In the lowlands this may be even longer. Costs of restoration vary considerably across geographical areas and depend on the types of interventions required. We propose various ideas for managing the costs and contractual arrangements associated with long-term land use change in our recent report with RSPB and the National Trust, Making Public Goods Pay[16]

Potential gains from de-stocking: Montgomeryshire Wildlife Trust’s Pumlumon project has successfully altered the management of uplands by reducing the density of grazing animals and therefore the damage they cause, yielding higher-quality livestock produce that sell for a premium which offsets any financial loss. In parts of the uplands, where sheep numbers remain too high to enable successful restoration, subsidies that drive stocking levels must be amended to promote good peatland management.

Re-wetting in partnership with Water Companies: In northwest England, blanket bog owned by United Utilities has been rewetted to reduce discolouration and improve water retention in catchments important for provision of potable water supplies. This reduces high treatment costs, and has the wider benefits of reducing or reversing oxidation of locked-up carbon, reducing fire risk and restoring biodiversity.

Learning lessons from current agri-environment schemes: Much restoration has to date been reliant upon funding from agri-environment schemes, which poses a number of difficulties for landowners including:

• Low payment levels: Agri-environment schemes offer capital payments for grip blocking and annual payments for the prescribed activities of moorland management and rewetting, subject to conditions for management of livestock, deer and vegetation. Payment rates (per hectare and per grip blocked) are calculated based on costs and income forgone which is challenging in areas with low-grade agricultural land.
• Challenges with existing scheme rules – including the requirement for significant expenditure which is claimable only in arrears and inflexible rules around the timings of capital works within a scheme.
• Late payments: late processing of payments by the Rural Payments Agency which damages relations with contractors who are owed payment.
• Duration of contracts and lack of read-across between incentive schemes: In Yorkshire, home to England’s only 4 sites registered with the Peatland Code offsetting scheme, none are yet active as activation requires landowners to enter into a 30yr management agreement and it is unclear whether this would preclude owners accessing agri-environment or other funding sources to assist with management.

Collectively these issues can discourage landowner sign-up and limit the delivery of large-scale restoration schemes. If future peatland restoration and the delivery of a peatland strategy are to be funded primarily through agri-environment schemes, these issues will need resolving. Wider financing mechanisms may be necessary to ensure that environmentally-sensitive land management is at least as profitable as other existing land uses, including grouse shooting and subsidised sheep farming in the uplands, and intensive dairy, arable and market gardening in the lowlands. This is critical given the importance to the national interest of healthy peatlands.

Calculating costs: Our recent report[17] estimates the annual costs of maintaining blanket bog habitats at between £34 million and £109 million/yr, with additional restoration costs at £56-62 million/yr over a 10-year period. Evidence in the wider literature suggests a wide range of restoration costs from £200-£7,000 per hectare, depending on the condition of the ecosystem, suggesting that the above estimates may be conservative[18]. The report includes ideas for a future Environmental Land Management Scheme (ELMS) and a case study on using alternative payment methods in ELM for the management and restoration of blanket bog (pp 60–66). The logic chain from the case study is presented below:

Managing competing priorities for peatlands:

• Biodiversity: Some degraded peatland sites provide important habitat for species which may be negatively impacted by peatland rewetting, for example in Lancashire this includes water vole, farmland bird communities and some nationally-scarce arable weed species. This should not preclude peatland restoration, but requires the creation of habitat suitable for these species and a network of ecologically-connected sites enabling species to move to new areas, as set out in Natural England’s Freshwater Habitats narrative[19]. 
• Afforestation: There may be conflicts between afforestation targets for England and the objective to rewet peatland to deliver carbon sequestration and other ecosystem services. Site-selection for planting schemes must exclude peatlands.
• Cultural landscapes: Similarly there may be issues around changes to ‘cultural landscapes’ and related impacts upon tourism; it will be important to involve the land-owning community in any decisions about the future management of land.

Three short case studies are provided in Appendix 1.

5.                   What should be included in the forthcoming England Peatland Strategy (EPS)?

We believe that the EPS should commit to the principle that funding for peatland restoration be sufficient, long term and spatially targeted through the Nature Recovery Network. Given the range of competing priorities and potential conflicts that will influence decisions about the future management of peatlands, the establishment of a statutory NRN to guide decision making has clear value. Quantitative, qualitative and spatial targets for peatland restoration and maintenance could be set under this framework at appropriate geographic and administrative levels – regions, counties, catchments. The NRN would inform the availability and level of funding, and guide the availability of advice and facilitation, to ensure that delivery in those areas where it will be most beneficial is promoted through appropriate levels of funding and support. Capital funding (through ELMS or a separate, dedicated fund) as well as management funds must be provided, given the need for both types of intervention when transforming our degraded peatlands. The restoration of natural processes should be a principle that underlies the development of a NRN as a means of promoting restoration choices that are inherently more sustainable. 

In relation to peatlands, ELMS needs to reflect the long-term nature of restoration via provision of a long-term phased funding stream. Catchment- or regional-scale plans and delivery are an option, backed by appropriate financial measures over 20-25 year timescales. Good models for this approach are already available through the work of regional peatland restoration programmes such as MoorLIFE, YPP and Pennine PeatLIFE. New approaches to ELM could be built around the lessons learnt from these landscape-scale programmes as well as from recent research[20]

ELM schemes should also build in monitoring over the lifetime of the restoration process, necessary to ensure the identification of refinements and repeat-treatment requirements at an early stage, thereby reducing the costs of further interventions later on.

The EPS should provide clarification over the availability of ELMS or other funding to landowners who partake in offsetting schemes. This would increase their appeal (and thereby their uptake).

The EPS should encourage the registration of additional sites under the Peatland Code which is necessary to both secure the future of UK peatland sites, and to create opportunities for UK companies to invest in carbon offsetting schemes at home, where currently they must look abroad. The statutory reporting of peatland carbon emissions would act as a driver for this process.

The EPS should include alternatives to full restoration including the sustainable use of farmed peatlands. For example, paludiculture is explicitly mentioned as a sustainable land use option in several global initiatives as well as in the IUCN UK Peatland Programme’s UK Peatland Strategy 2018-2040. However, the UK is yet to adopt the initiative into national policy, and there is no explicit mention of wetter farming or reference to paludiculture in the UK Government 25-year Environment Plan. This may, at best, discourage and at worst actively prevent landowners/users from moving away from drainage-based use of lowland peatlands towards wetter ways of farming that land. 

The EPS should restrict the establishment of new IDBs in peat-dominated catchments. Currently there remains pressure on Internal Drainage Boards to lower drain beds and water levels as peat disappears, because the water table gets nearer the surface as the peat erodes - this lowering promotes peat oxidation and degradation, leaving the landscape less able to hold water and exacerbating flooding issues. There needs to be a shift away from this damaging cycle of pumping water out of peatlands, to more sustainably manage habitats that retain water in the landscape.

The EPS should commit the government to an early statutory date for the cessation of the extraction, import and use of horticultural peat in the UK, underpinned by a public awareness campaign. As the UK is a major market for peat extracted for horticulture in Ireland and eastern Europe, this would be beneficial in protecting the peatland resource both in the UK and around the world.

September 2019

Appendix 1 – Examples of the cost of Peatland restoration

Example 1: Land Purchase

In many cases, land purchase may be a necessary component of peatland restoration. Lincolnshire Wildlife Trust have costed a potential project to secure and restore a wetland system at Bourne North Fen, a 50ha Grade II arable and pasture site, estimating that the cost of buying and restoring the fen would be ~£2M. This cost is based in a large part on land valuation figures which make up nearly half this cost. The high value of such land needs to be taken into consideration so that private landowners who provide public goods through the restoration of their land, do not see an overall decrease in the value of their assets.

Example 2: Yorkshire Peat Partnership capital and revenue costs

Yorkshire Wildlife Trust, through Yorkshire Peat Partnership, Pennine PeatLIFE and the DEFRA fund have so far delivered capital restoration works on 32,343ha of upland peatlands costing a total of £16,153,150 which is an average of £500/ha.  However, this only takes account of the initial capital restoration works. Recent analysis by Yorkshire Wildlife Trust of sites being put forward for the Peatland Code showed that for a heavily eroding 16ha site there were estimated ongoing costs after the initial capital phase for 20 years of about £193,973 which would be an additional £606/ha/yr bringing the total capital costs over the 20 year lifetime of a restoration project up to £12,623/ha.

On top of this the revenue costs to delivering this capital work needs to be accounted for. Yorkshire Wildlife Trust suggest that, for the initial capital phase this is about 15% of the capital (excluding any monitoring, research or awareness raising) which would be an additional £90/ha.  This would then need to be followed by a period of monitoring and management of the follow-on capital works for 20 years which is estimated by Yorkshire Wildlife Trust to be £159/ha/yr. This is a total revenue cost of £3270/ha over the 20 year lifetime of the project.

This is a total 20 year lifetime cost of £15,893/ha to restore heavily eroding upland peatland.

Example 3: Fen restoration with beavers

Kent Wildlife Trust’s Ham Fen Nature Reserve is the last remaining fen in Kent. The 100acre reserve was recently extended by an additional 33acre land purchase following a fundraising appeal. It forms part of the 700 acre Hacklinge peat basin at the eastern end of the Stour Valley.

The site had escaped agricultural intensification because it is the sump for the surrounding basin and therefore the hardest area to drain. Despite this, invasion by secondary woodland meant it was severely degraded and almost dry. It proved unsustainable (financially and otherwise) to continue attempts to restore the site through volunteer and contractor efforts alone, so the decision was made to use beavers on the site – the first reintroduction in England.

Beaver have not been without their problems but have completely transformed the site, facilitating the return of fenland species previously thought to be lost.

Subsequently KWT secured funding from the Coca Cola Replenish Fund to restore a small area of fenland separated from the main reserve by a road. This restoration of 1ha involved the removal of 30cm topsoil across the whole site, bunding and the restoration of a previously canalised channel into meanders, costing £40,000.