Fauna & Flora International: Written Evidence to the Environmental Audit Committee Inquiry into Biodiversity and Ecosystem Services
Fauna & Flora International (FFI) is the world’s oldest international wildlife conservation organisation, founded in 1903. Our mission is to conserve threatened species and ecosystems worldwide, choosing solutions that are sustainable, based on sound science, and which take into account human needs. Headquartered in Cambridge, UK, we work in more than 40 countries across Africa, the Americas, Eurasia and Asia-Pacific, working with over 300 partners including governments, businesses and local civil society groups on over 140 conservation projects.
FFI welcomes the inquiry into biodiversity and ecosystems by the parliamentary environment audit committee. But it is important to start with clarity of what these terms refer to. FFI understands ecosystems as biological communities of organisms (including people) interacting with each other and their physical environment. The (ecosystem) services these interactions generate ultimately support almost every aspect of human society. Biodiversity refers to the level of diversity of life within these systems. The level of diversity (living and non-living) plays an important role in ecosystem productivity, adaptability and resilience. If ecosystems are considered an asset, biodiversity is one measure of the quality of that asset. Whilst the formal definition of biodiversity is commonly cited, in common parlance, including major international reports, the term ‘biodiversity’ is more often used to describe something broader than a measure of ecosystem quality. It is more generally taken to refer to all life, used interchangeably with broader terms such as ‘nature’. FFI is ultimately concerned with the conservation, management and equitable use of nature, but recognises the maintenance of high diversity within nature as a crucial component of this.
In the last 50 years, the impacts of human activity on these systems has outstripped their inherent capacity to regenerate and recuperate. Some of the most immediate implications of this imbalance, such as the impact of greenhouse gases on planetary temperatures, are now being recognised and acted upon. Other implications, such as the declines in biodiversity and the associated losses of ecosystems and their services, are have taken longer to acknowledge, being infinitely more complex and much harder to monitor. Yet all these implications are interconnected and systemic in nature. Global heating is exacerbating biodiversity loss and ecosystem collapse. Biodiversity loss and ecosystem degradation is exacerbating global heating and reducing resilience to the effects of global heating. The people most likely to be driving the changes tend to be the richest and best equipped to adapt. The people most likely to suffer the initial consequences are those that are poorest and most vulnerable change.
Awareness and action on biodiversity and ecosystem loss has been growing steadily. The Sustainable Development Goals recognise life on land and in water as two of the 17 tenets of sustainable development. The Convention on Biological Diversity is setting new targets for the coming decade. TEEB and now the Dasgupta Review have introduced a new ‘grammar’ to help policy makers understand the economic value of biodiversity whilst the World Economic Forum and others are working to develop the business case for action for the private sector. But it is not enough to see biodiversity and ecosystems as one goal of sustainable development, particularly when other goals can be contradictory. It is not enough to set loosely defined international targets for biodiversity and then to spend less on delivering the targets than is spent subsidising the very activities that are most responsible for biodiversity declines. It is not enough to base political and financial decision making on biodiversity only on the cases where economic value can be quantified. And it is not enough to see biodiversity loss as just ‘the next climate change’ risk for business and finance. Ecosystems, and the biodiversity that comprises them, are the heart of the system we call our environment, a system we are both embedded in and wholly reliant upon. Recognition of their fundamental importance to not only the well-being but also the survival of human society is crucial.
The answers given to the requested questions do not necessarily represent FFI thinking as a whole and do not attempt to be complete answers. Instead we focus on giving a general position and try to provide evidence the committee may not find elsewhere if available to us.
The state of biodiversity
- How effectively is the Government monitoring the impact of UK activities on biodiversity, at home and abroad?
- All monitoring is inhibited by the complexity of the subject. It is very difficult to obtain a single measure of ‘biodiversity’. All proxies available have inherent biases. There is a strong focus on species diversity for example (rather than genetic or assemblage diversity). There is also particular focus on red list (rare) species, which risks overlooking the decline of more common but probably functionally more important components of ecosystems. There are also taxonomic biases, with larger, terrestrial vertebrates and plants better understood but invertebrates and water-based taxa far less so. Reporting is also inconsistent and baselines often poorly established. The issue of shifting baselines means we don’t have a whole picture of what the diversity and abundance should be, and a focus on limited indicator species and the previously rare means huge shifts in populations are going undetected lower in the food chain.
- In the sea monitoring is focused on a few commercial species and fails to recognise the wider impacts of activities such as bottom trawling on the wider biodiversity, and future productivity, of the seas.
- Monitoring in OTs is very much supported by some UK charities and mechanisms such as the Darwin initiative and could be substantially strengthened
- In other countries the real impact of UK activities are poorly recognised in terms of damage caused by resource extraction and supply chains for commodities consumed in the UK – effectively offshoring our total biodiversity impact as well as offshoring the concomitant carbon impacts (e.g. from forest destruction)
- It would be good to emphasise disproportionate access to environmental benefits and disproportionate negative impacts of mis- and overuse of resources/pollution on BAME and POC communities, at home and overseas. Resource prioritisation could look at these intersectionalities. And should be considered in future assessments of impact/monitoring.
- Need to consider the hidden biodiversity impacts of pollution – both chemical and plastic – on biodiversity both in the UK and overseas – we have no real understanding of the scale of damage unrelenting use of chemicals is having on the environment.
- How has the Government performed against the Aichi Biodiversity Targets and what further progress is needed?
- Poorly, along with most of the world – the targets were challenging and ambitious, but proportionate to the scale of the threat and still nations around the world have not mobilised change at anything like the scale needed
- Where should the four nations prioritise resources to tackle biodiversity loss?
- We need biodiversity-first and carbon-first decision making if we are to avoid the coming combined and inter-related impacts of biodiversity loss and climate change. Decisions at every level should be assessed against clear biodiversity impact criteria, and the necessary actions should not then be discounted purely on economic terms given the long term harm these decisions. We need some clear red lines around biodiversity protection, rather than the clear undermining of current biodiversity intentions – such as recent proposed changes to planning in England and the removal of sustainability as a key ambitions in UK fishing.
- The UK administrations should be willing to mobilise and empower a much wider engagement in biodiversity protection by enabling local organisations to have more role in delivering biodiversity protection in the areas that they live closest to.
Evaluating measures to conserve and enhance biodiversity
- How should the Environmental Land Management scheme maintain and improve biodiversity? What role might alternative land use play in delivering improvements to biodiversity under the ELM scheme?
- The ELM has the opportunity to rebalance the needs of biodiversity and food production. The model needs to consider its approach as to land sparing (ie some areas for biodiversity and some areas intensively farmed) vs land sharing (lower impact agriculture over a wider area), and decisions with this regard need to be explicit to avoid a system that fails to deliver the expected dual benefits. In considering other land use options, there may also be play offs between short-term carbon sequestration (and these need to be considered in the frame of carbon release when for example trees are then felled) and biodiversity value – moving away from a system that looks at short-rotation monocultures, towards long-term planting of more biodiversity rich woodland is key, focusing on potential recreational and health values over timber harvest revenue. In all of this the value of existing old growth woodland and other near-natural systems, in terms of both biodiversity value and potential carbon capture, must be absolutely prioritised.
- How effective are the new measures to enhance biodiversity within the Environment Bill, particularly biodiversity net gain and Nature Recovery Networks? Do these measures complement existing regulatory frameworks and address issues surrounding how to value nature?
- In principle these are very exciting, but the devil will be in the detail, including the incentive packages that are developed and the investment needed in appropriate monitoring activities.
- How should Nature Recovery Networks be planned, funded and delivered?
- These need a holistic cross-sectoral approach embedded in wider land use approaches, but prioritising the ways that they can support and maintain old-growth habitats rather than just creating new wilder areas. They should be focused on reconnecting existing refuges for biodiversity, and these need adequate protection in planning to avoid permitting development of these and just offsetting with lower value new planting.
- It would be good to see more emphasis on working with all local community infrastructures and institutions in the development of these networks, not just landowners and farmers.
- How effective are other policies for conservation and enhancement of existing natural habitats, such as the Woodland Grant Schemes?
- These are complex schemes and still tend to lead to a focus on monoculture planting with few wildlife benefits. Grants should be prioritised for management of existing old-growth woodland and for the planting of naturalistic mixed woodland, with added incentives for additional biodiversity enhancements.
Co-ordination of UK environmental policy
- How can policy be better integrated to address biodiversity, climate change and sustainable development?
- Ensuring every decision is considered against these three criteria first, with clear red lines to avoid economic and political decisions always being prioritised. Recognising the irreplaceability of biodiversity and limited role of offsets within an application of a mitigation hierarchy would lead to much clearer recognition of the future harm being done for short term decision making. Where there are trade offs between these three criteria, then a clear assessment of future cost vs present cost needs to be undertaken.
- How can biodiversity and ecosystems help achieve the air, soil and water quality objectives in the 25 Year Environment Plan?
- Biodiversity is essential for all these basic ecosystem processes, and while it continues to decline our ability to maintain these life support systems will continue to reduce, requiring large scale and costly technical interventions which can only provide a temporary solution to an escalating crisis, the impact of which will be felt by our children and grandchildren. Without putting biodiversity first in all decision making at this stage, the impacts for future generations in having to find new ways to keep populations healthy and fed could prove unsurmountable.
- How well is the UK addressing biodiversity loss in its Overseas Territories and in international development partnerships with other countries?
- The Darwin Initiative is testament to what UK financial assistance can do to help countries manage their own biodiversity and address their own CBD commitments. However this is only a drop in the ocean. Previously DfID had failed to effectively integrate biodiversity considerations into its work, and it is not yet clear how biodiversity will be integrated into FCDO’s agenda or into future aid budgets.
- The marine networks around the OTs are impressive but in stark contrast in the failure in domestic waters – inkling this week’s shocking removal of sustainability from the UK fisheries bill
- What outcomes and protections should the UK Government be pushing for at the forthcoming UN negotiations on the post-2020 global biodiversity framework at the Convention on Biological Diversity COP 15?
- The UK should be promoting ambitious global agendas such as 30by30, but also should be working with countries to help those with the highest biodiversity value – and where the actions of the UK in history have contributed to habitat loss or degradation, to develop ambitions nature recovery plans.
Economics and biodiversity
- What are the possible approaches to balancing economic growth and conservation of nature and its contributions? Is there evidence these approaches work and can be implemented?
- Ecosystems and biodiversity ultimately underpin every aspect of our economy. Part of the reason we have lost so much is because our economic systems fail to recognise this. Nature is generally treated as having low, or no, economic value. The destruction of nature is therefore generally the result of an economically rational decision whilst the conservation of nature is often an economically irrational decision.
- Recognising the economic importance of ecosystems and biodiversity is a vital step to address this. However, the limitations of doing so must also be recognised. Valuations of nature generally focus on valuations of the services we derive from an ecosystem. It is much harder to value the underlying asset - the ecosystem – and it is harder again to place a value on the level of biodiversity within that ecosystem. Economic valuations of nature will therefore almost always be gross underestimates of ‘true’ value. Recognising the existence of some economic value can help decision making, but economics cannot be the basis of all decision making on nature.
- Economic valuation of nature should only be used in conjunction with the setting of societal ‘red lines’. Just as it is understood that no global warming would be preferable, but that 2 degrees is the societal / political decision on the maximum level of risk society is prepared to accept based on scientific evidence of the likely impacts of global warming, so a societal agreement on the minimum amount of ecosystems and corresponding biodiversity we need to retain needs to be agreed, based on scientific evidence of the likely risks losses would cause. Economic valuation can then be applied in addition to this, guiding prioritisation of actions.
- What does the UK Government need to do to maximise human prosperity – in terms of health, economic, and social wellbeing—within the ecological and resource constraints of a finite planet? What alternative models and measures of economic welfare can feasibly help achieve this?
- Kate Raworth’s doughnut model is one of the best for capturing the desire for maximising human prosperity within the environmental boundaries of the planet.
- Looking at meeting basic needs and non-material sources of human wellbeing and satisfaction; the current consumerist model prevents any chance of limiting resource use as needed and is contributing to a decline in mental health; defining different metrics of success could help recalibrate the agenda towards more sustainable pathways. Helping people find fulfilment in other ways beyond the accumulation of material possessions and wealth, and moving ambitions towards a basic standard of living but focusing on security, happiness, personal growth and fulfilment rather than just the need to secure the next meal.
Pairing nature-based solutions to climate change with biodiversity
- Which nature-based solutions are most effective in achieving both climate and biodiversity goals?
- Maintenance of old growth forest and prevention of activities that are actively releasing emissions (such as peat harvesting, rainforest destruction, burning of moorlands, and bottom trawling)
- Biodiversity-friendly restoration which takes into account the current and natural status of habitats and doesn’t incentivise counterproductive decisions (such as tree planting on chalk grasslands)
- Developing habitat restoration activities which fully integrate and plan for biodiversity as part of a landscape mosaic approach where connectivity is prioritised
- In climate and biodiversity solutions there is huge potential in marine restoration activities – native oyster restoration projects developing in Scotland (Loch Craignish, the Clyde, established e.g. in Dornoch), seagrass restoration, and need to protect kelp forests.
- The IUCN Global Standard for Nature Based Solutions lists a net gain to biodiversity and ecosystem integrity as one of its 8 principles. The most effective projects will be those that also address the other 7 principles ie those that:
- Address societal challenges (involving all stakeholders and rights holders in their design)
- Are informed by scale (geographic, economic and cultural)
- Are economically viable (recognising and accounting for the fact that most provide long term benefits for many, but often at a short term cost for others)
- Are based on inclusive, transparent governance processes (both for inherent sustainability but also license to operate)
- Balance trade-offs between their primary goal and co-benefits (recognising all costs and benefits but also the ecological and social boundaries that cannot be traded off)
- Are managed adaptively
- Are mainstreamed within an appropriate jurisdictional context, aligning with existing policy frameworks
- What would constitute clear indicators of progress and cost-effectiveness of nature-based solutions and how should trade-offs and co-benefits associated with nature-based solutions, biodiversity and socioeconomic outcomes be considered?
- Landscale is a new tool from Rainforest Alliance which presents one way of measuring and monitoring sustainability performance at a landscape level
- How can funding be mobilised to support effective nature-based solutions to climate change? How can the private sector be encouraged to contribute to funding?
- Given the amount of funding required to adequately conserve sufficient biodiversity and ecosystems is so large, the key roles for public policy and finance are a) to create the enabling environment to allow for increased private financial flows and b) to remove the subsidies that work against biodiversity and ecosystem conservation.
- Blending public with private finance seems to be one of the most effective ways of directing finance to nature. Public finance can de-risk and build confidence in a project, creating the enabling conditions for private finance to take lower risk, shorter term investments. The TLFF $95m sustainability bond set up with rubber plantation PT Royal Lestari Utama, Michelin and USAID is a good example of how this can work.
- New research from IIED explores the potential for increasing the role of debt for nature swaps in funding conservation