Game & Wildlife Conservation Trust submission to the Environmental Audit Committee’s call for evidence on Biodiversity & Ecosystems


The Game & Wildlife Conservation Trust 

We are a leading, independent UK wildlife conservation charity conducting scientific research into Britain’s game and wildlife to enhance the British countryside for public benefit.  We use our research to provide training and advice on how best to improve the biodiversity of the British countryside.  We employ 22 post-doctoral scientists and 50 other research staff with expertise in areas such as birds, insects, mammals, farming and farmland ecology, fish and statistics. We undertake our own research as well as projects funded by contract and grant-aid from Government and private bodies. The Trust is also responsible for a number of Government Biodiversity Action Plan species and is lead partner for grey partridge and joint lead partner for brown hare and black grouse.  In addition the Allerton Project, our demonstration farm in Leicestershire, undertakes research into the effects of different farming methods on wildlife and the environment, and shares the results of this research through educational activities for practitioners and the public.   



Terms of Reference:

The Trust is submitting evidence to this inquiry as we believe our work is core to this area of policy consideration and our research a valuable contribution to the debate.  Our approach to conservation is neatly encompassed in our recent focus on “Working Conservationists” and in our belief in the principle of “conservation through wise use”.  


In our answers below we seek to address the questions posed from this practical perspective, in particular giving consideration to the need for policy to engage with land managers and farmers and motivate them in order to encourage effectiveness and success; as evidenced by the successes achieved by our working conservationists (


Given our background our answers will focus on the domestic aspects of the terms of reference below.



Whilst we have addressed the questions posed below in turn we would like to take this opportunity to emphasise five key points:

  1. Conservation efforts need to focus on policies promoting farmer/land manager engagement across the wider countryside and adaptive, outcome based management measures rather than protection and prescription.
  2. Establishing targets and designing monitoring metrics to support them is a pointless exercise unless practical actions are available to deliver them.
  3. The current migration to natural capital assessments is welcomed but until all public goods/ecosystem services are appropriately valued, Government policy needs to ensure a level ‘funding’ playing field.
  4. A land use strategy is needed to coordinate the delivery of the multiple outcomes that policy now expects of our finite land resource.
  5. We need a soil strategy to support our land based ecosystem and food production system and to make soils more resilient in the face of climate change whilst protecting economic considerations.


The state of biodiversity:


Domestically there is extensive collection of metrics to support the assessment of biodiversity but we question whether they are always the right metrics and how effectively they cover the broader landscape (i.e. outside the nature reserves and replicated, scientific surveys that underpin much of the species and habitat monitoring to date).  Linking in with our desire for a more bottom up approach to conservation practice would be the use of practitioner surveys (i.e. involving farmers and land managers etc.) to provide a more comprehensive picture of biodiversity levels.  Whilst this data may not be scientifically robust (i.e. methodologies might differ slightly by individual) it would provide good trend data, particularly at the local levelThe Trust’s grey partridge count scheme is a good example (



Data collection to monitor biodiversity is all well and good if there is also action to address failures and to meet targets – as opposed to targets just being re-defined.  The UK Biodiversity Indicators Revised 2019 report demonstrates that whilst the area under environmental management and extent of protected areas has improved, species abundance and distribution has (generally) not, as demonstrated by the statistics related to UK priority species and species of the wider countryside.  Consequently the Aichi targets relating to the improving status of biodiversity (Strategic Goal C) and reducing direct pressures on biodiversity whilst promoting sustainable use (Strategic Goal B) are not being satisfactorily addressed. This concern is supported by the Sixth National Report to the United Nations Convention on Biological Diversity in January 2019 which concluded that in only 5 out of 20 targets was the UK on track with none of these contributing to the critical (in our opinion) Strategic Goal B.



The reasons for the disconnect between habitat provision and species recovery highlighted above needs addressing to make further progress and this is where we feel the four nations should prioritise resources. Statistics such as the UK Biodiversity Indicators demonstrate that the current approach of protection and prescription has largely failed to arrest the decline.  The four nations should consider a more enlightened approach based on greater flexibility and adaptive management to species conservation.  To date policy has assumed that species conservation depends on the provision of its habitat. This is not always the case as species’ lifecycles can be compromised by other factors such as climate change, pesticides or predation. Successful conservation policy should be flexible enough to address these other factors too.


Evaluating measures to conserve and enhance biodiversity:


In responding to Defra’s recent consultation on the proposed ELMS we emphasised the need for ELMS to inspire and sufficiently reward farmers and land managers, as they are the foundation to the schemes success. A bottom up approach, with the focus on outcomes rather than management prescriptions, is most likely to ensure this success. Natural England’s current trial on results-based payments and ELMS Tests and Trials will go towards informing such an approach as should initiatives such as our own grey partridge recovery project or working conservationist case studies.  These demonstrate situations where individual success has been achieved using the Government funded agri-environment scheme as a basis, supplemented by additional management measures, such as sustainable farming methods or predation management, which our research has scientifically proven will contribute to conservation successFurthermore the encouragement of collaborative conservation, such as Farmer Clusters, would encourage the provision of measures at a broader, landscape scale. We discuss this further in the delivery of NRNs below.


Past barriers to agri-environment scheme uptake include single entry dates for applications to the schemes, over-prescriptive rules and regulations, constant re-mapping of land areas with excessive granularity, delayed payments, a formula which only rewarded income forgone and costs incurred and an inflexible inspection regime which targeted participants indiscriminately rather than focussing on wilful breaches. This has conspired to de-motivate landowners from participation and caused a decline in the initial 70% uptake achieved by Entry Level Stewardship at inception.  The attractiveness of ELMS and therefore its take up will be an important contributor to achieving biodiversity targets, because to get the outcomes we aspire to achieve will require mass participation.



Alternative land uses could complement ELMS through providing a blended finance approach to biodiversity improvements.  Sporting land uses provide the incentive to undertake a range of environmental practices, including less commercial management activities such as coppicing, that are proven to support a wide range of species, some red-listed, and protect important habitats.  As we stated in our ELMS consultation response we feel it is important that the farmer/land manager can “trade on their environmental good delivery” and get paid by another customer (in addition to solely government).


Encouraging conversion to an alternative land use often referred to as Treescapes would depend upon scale.  We are in the process of responding to the Tree Strategy consultation in which we will make the point that small scale schemes have the potential to greatly contribute to policy aims and therefore woodland support grants (either ELMS or WGS) need to be flexible in terms of size and planting density.  Field corners and trees within hedgerows are possible options but their contribution to biodiversity would be dependent on their location in the wider landscape.   If they were located in open landscapes, which species such as grey partridge require, this would have an adverse effect.



Both mandating biodiversity net gain and the establishment of Nature Recovery Networks, building on the “bigger, better, more and joined” conclusions reached in the Lawton Review, are welcome measures.  However their effectiveness will be in how they are delivered.  There is much encouragement to involve the local communities in the delivery of NRNs, which we feel is important.  But it is most important that the landowners are engaged in the process and enthused to deliver the outcomes.  How biodiversity net gain from development is implemented remains uncertain, although the Trust is supportive of the aspiration. In the past biodiversity was not considered in planning beyond the conservation of European Protected Species. We are not aware as to how the “net gain” will actually be monitored or the required longevity of the gain.


In considering how effective these measures might be it is important to reflect on the situation to date.  Despite Biodiversity 2020 and other biodiversity action plans key native species continue to decline suggesting that the focus on habitat delivery (in the wider countryside and via protected area status) has not worked adequatelyThis is likely to be due to a combination of lack of planning where key habitat provision is needed (potentially addressed by the NRNs and other spatial proposals); a lack of focus on other pressures on species such as predation and, in the case of farmland birds, a shortage of winter feed; and, an inability to adapt policy to changing situations and different ecological challenges.  Our view is that policy in this area needs to be flexible and focussed on outcomes rather than just management inputs.  This means, for example, that considering predation management alongside habitat provision should be core to species recovery where it has been scientifically proven to be effective. The Trust has demonstrated this combined approach unequivocally by increasing the local population of open-cup nesting species, such as song thrushes, and ground nesting species such as grey partridge, lapwing and curlew, all currently Red Listed species. Where predation control measures are withdrawn population decline recommences, often leading ultimately to local extinction. In these circumstances habitat provision alone is simply not enough.



Whilst individual NRN objectives will largely be delivered via ELMS options, planning their spatial delivery should include encouraging the involvement, and creation, of Farmer Clusters ( The GWCT has been involved with the concept from the very beginning, helping to establish the ground-breaking farmer-led Marlborough Downs Nature Improvement Area project in 2012, and then the first pilots of ‘Farmer Clusters’ in partnership with Natural England in 2014. By working together, supported by an advisor or ‘facilitator’, farmers and land managers can collectively deliver greater benefits for soil, water and wildlife at a landscape scale.  Such an approach can also allow the cluster to pursue private sources of funding and to develop natural capital approaches to public good delivery, thereby facilitating a blended finance approach to NRN funding.


Involving local communities in NRN planning and design is a key principle.  This should be taken further to include local people being involved in the monitoring of the NRNs delivery.  At the outset we drew attention to the need to involve practitioners in the monitoring of our biodiversity in the wider countryside.  Involving local communities in citizen science initiatives would ensure continued engagement with the NRN.



If NRNs are to act as a strategic spatial prioritisation framework they will need to promote the right measure in the right place.  Trade-offs between biodiversity, economic necessity and other public goods such as carbon sequestration need to be considered on a site by site basis and not the subject of a top-down approach (see next section).  The point we made above about encouraging small scale tree planting schemes reflects the need for tree planting to consider a wider environmental agenda than just carbon sequestration.  There is a very real concern that to meet the targets currently proposed inappropriate tree planting would be encouraged, resulting in changes to local ecosystems and the biodiversity contained therein.  The right tree in the right place is an important focus to avoid making biodiversity objectives ineffective. Other points we make in our response to the Tree Strategy that are pertinent here are:



Co-ordination of UK environmental policy:


We favour the adoption of a land-use strategy to make “the best use of land” as proposed by the Committee on Climate Change[1] -  “A future land strategy that delivers the UK’s climate goals whilst balancing other pressures will require fundamental changes to how land is usedAs we have a finite land resource, we need an over-arching strategy to coordinate the multi-functional land use necessary to maximise the benefits delivered; in other words we need to see how the pieces of the environmental and agricultural jigsaw fit together and whether they create the outcome envisaged. Invariably there will be trade-offs but they will be different for each hectare and so an overall strategic approach to how benefits should be balanced and initiatives coordinated is needed. Such an approach would also reflect the complexities of combining biodiversity and ecosystems with delivering the air, soil and water quality objectives in the 25YEP. 


The individual strategies (e.g. Tree, Peat, Nature, Air etc) that are currently being produced would be seen as best practice delivery guidance. Given that many of our natural assets are the subject of individual strategies we remain concerned that soil is the single exception.  Soil underpins our entire land-based ecosystem and our food production system and so the lack of a strategy is in our opinion a failing of the current approach to UK environmental policy.  Whilst the improvement of soil health is a stated 25YEP objective there has been no practical initiatives to deliver this.  The pledge to identify the metrics which might be used to define a healthy soil will do nothing to facilitate actions that lead to improved soil health.  As we have stated before metrics are all very well if they are acted upon.  We need measures that deliver practical options for farmers/land managers to incorporate into their farming systems that will improve soil health.  Soil health should not go the same way as farmland birds whose demise has been successfully monitored for decades. The yield plateau being experienced in most cropping systems is limiting our ability to meet increased domestic demand and this increases our food insecurity and ultimately will lead to the increased cost of food. Soils which are highly biologically active are more productive and resilient in the face of climate change and therefore have the capacity to produce more food at lower environmental impact and cost thereby facilitating the combined objectives of economic growth and biodiversity (see next section) 



Biodiversity and ecosystems are complex systems of which air, soil and water are key constituents, so emphasis on the former will underpin improvements in these natural assets.  Focussing on biodiversity and ecosystems will therefore encourage an integrated approach to policy delivery rather than a silo approach. 



We have not responded to these questions as they are not in our area of expertise


Economics and biodiversity:


The production of a soil strategy that underpins productive and resilient soils and defining biodiversity in a way that acknowledges its functional value to provisioning, supporting and regulating ecosystem services as well as its cultural value (i.e. species conservation) would help to encourage an integrated approach to economic growth and nature conservation.  How such an approach might work is already evidenced at individual farm level through some supplier/farmer collaborations.


The demand for ever lower cost ingredients has driven agricultural intensification which in-turn has impacted upon biodiversity. However, some suppliers are recognising the wider role they can play in enhancing the environment from where their ingredients are sourced.  Examples include Fair to Nature/Conservation Grade, where the certified farms create specific wildlife habitats, such as pollinator or farmland bird habitats, on at least 10% of their land and follow the unique sustainability protocol, and two other approaches that the GWCT has been involved in with Kelloggs and Nestle.


At Kellogg’s the objective is to raise business and environmental performance con-currently, with a special focus on farmland biodiversity.  They established a Producer Group which engages independent experts to provide knowledge and advice through farm visits and reports, study tour tips and seminars. Kellogg’s do not pay a premium for the wheat they buy, but club membership and benefits are provided at no cost to the farmer participants.


Nestle has created a bespoke web-platform to which the farmer members up-load details of the environmental measures they have carried out on their farms e.g. pictures of their tree or hedge planting. Each measure is automatically given a points value and when this exceeds 3,000 it triggers a premium payment of 0.005 pence per litre on the milk supplied. For an average farmer with 200 cows producing 10,000 litres per cow per year this is worth £10,000 p.a.   


The land sharing/land sparing debate has detracted from an integrated, ecosystem services approach to land use.  We support the view that they “are not mutually exclusive, as both are needed to balance management needs for the multi- functionality of agricultural landscapes[2]. Focussing intensive production in the field centre whilst taking the least productive/marginal 10-13% out of production and managed for “biodiversity and ecosystem provision” would improve crop yields per hectare whilst also improving farmland biodiversity (as proven at the Allerton project (  Such an approach is favoured in contrast to organic farming which is often seen as the answer to the question of balancing economic growth and biodiversity.  As we have stated in other fora, the estimated 40% reduction in gross output across the rotation means that such an approach would come with significant trade-offs (including increased GHG emissions)[3] and areas of land elsewhere on the planet which support high levels of biodiversity, particularly areas of natural or semi-natural habitat, are not put under pressure by a need to increase food production to make up for de-intensification elsewhere[4]. Certified organic land currently occupies a mere 2.6% of UK farmland and is consequently insufficient in scale to deliver the biodiversity increases required to meet our targets.   Intensive agricultural production systems can improve their environmental footprint and Government intervention through ELMS and other capital investment programmes should encourage improved agronomy, genetics and investment in technology and precision farming techniques. 


We have not responded to this question as it is not in our area of expertise.





Pairing nature-based solutions to climate change with biodiversity:




The IUCN definition of NbS is “actions to protect, sustainably manage and restore natural or modified ecosystems that address societal challenges effectively and adaptively, simultaneously providing human well-being and biodiversity benefits”.  

In the Trust’s response to the Committee’s Future Inquiries inquiry we highlighted some of the concerns we have about the effectiveness of NbS in achieving multiple goals.  Tree planting is considered a nature-based solution but as we have highlighted above it will only address multiple objectives if policy, WGS and other funding sources, such as the use of biodiversity or environmental credits, guide the right tree in the right place approach to avoid afforestation with non-native monocultures. 


Instead of going for these “easy win” approaches Government should promote NbS solutions that involve the greatest area “under management” whilst minimising impacts on existing ecological systems i.e. work with what we have got such as sustainable or nature-friendly farming or agroforestry (evolutionary approach) rather than encourage widespread adoption of measures which would fundamentally alter the landscape (revolutionary approach). 


We emphasised in our response to the ELMS consultation that nature-based solutions should be a key focus. The reasons for this approach are best provided by an example.  The purpose of a beetle bank is to provide biological pest control services to the farmer and to reduce the need to use insecticides, which are shown to disrupt the in-field ecology and which have an “environmental cost”. However, a well sited beetle bank can also provide habitat for bumble bees (pollination services), earthworms (which enhance soil health and structure), field and harvest mice, nesting sites for farmland birds, provide a barrier to surface run-off and erosion (especially if positioned across the slope), allow water infiltration while also potentially supporting carbon sequestration objectives by locking up carbon through dead plant material, although this has yet to be scientifically proven.  Engaging effectively with farmers and land managers through ELMS and WGS would help deliver a more broad based approach to NbS both in terms of multiple outcomes and scale.


To avoid maladaptation, policy should be led by weight of scientific understanding and promote an adaptive approach to policy objectives.  This will help ensure that NbS solutions are more effective in minimising trade-offs between objectives.


Whilst the current focus on NbS is welcomed, measuring its cost effectiveness and success will be reliant on natural capital approaches which we are concerned are not yet developed enough to appropriately monitor progress and encourage private funding initiatives.  In some areas metrics and therefore associated ‘marketplaces’ are available and developing e.g. carbon sequestration, but many ecosystem services lack a supporting economic infrastructure such as biodiversity.  Consequently it will be important for Government to provide support in these areas to ensure a level ‘funding’ playing field.   In addition, given the complexities of valuing biodiversity (i.e. do you value an individual species or a suite of species or the habitat they occupy?) it would be regrettable that more focus is made on the metrics than the outcomes.  We suggest that there needs to be a focus on how biodiversity should be valued to ensure that it is not overlooked in the move to natural capital accounting. 


Having said that the food chain is one area where private funding initiatives that support biodiversity outcomes do already exist as demonstrated above with the Nestle scheme in particular.  Companies such as Nestle and Unilever have set carbon targets and are already looking at how they can reduce their footprints across the supply chain.  This will involve UK farmers and so it will be important that the new ELMS allows participating farmers to “trade on their environmental good delivery.



September 2020




[1] Land use: Reducing emissions and preparing for climate change Committee on Climate Change November 2018

[2] Grass I, Loos J, Baensch S, et al. Land-sharing/-sparing connectivity landscapes for ecosystem services and biodiversity conservation. People Nat. 2019;1:262–272.

[3] Smith et al 2019 The greenhouse gas impacts of converting food production in England and Wales to organic methods NATURE COMMUNICATIONS | (2019) 10:4641 | |

[4] Green at al 2019 Land sparing to make space for species dependent on natural habitats and high nature value farmland · Proceedings of the Royal Society B: Biological Sciences 286(1909):20191483DOI: 10.1098/rspb.2019.1483