Written evidence on behalf of the Association of Local Environmental Records Centres (ALERC)
About ALERC and local environmental record centres
- Established in 2000, the Association of Local Environmental Records Centres (ALERC) is a not-for profit social enterprise which exists to promote and support the interests and efforts of the network of local environmental records centres (LERCs) across England, Wales, Scotland and Northern Ireland. We advocate for and develop good standards of practice in the collection, collation, management, dissemination and analysis of environmental data, and their use locally and nationally.
- LERCs exist in a variety of forms, reflecting local history and their circumstances. Most are based with local authorities or county wildlife trusts, with some hosted by museums or entirely independent. This helps them to meet local needs, whilst operation in accordance with agreed and accredited standards facilitates interoperability of data for wider purposes.
- LERCs play a vital role in supporting the efforts of local recorders and recording groups and in ensuring that individual records can be turned into consistent environmental datasets of known quality which can be made available to inform and support local authorities’ planning the efforts of conservation NGOs and other landowners, as well as providing information to the public and helping to involve them in future recording and skills development. Amongst other things LERCs play a significant role in involving member of the public in local decision making and democracy
- ALERC is a member of the State of Nature Partnership and LERCs and ALERC also form part of the wider National Biodiversity Network which cuts across a range of sectors involved in the collection, curation, management, analysis and use of environmental information and the activities which facilitate these.
The state of biodiversity:
How effectively is the Government monitoring the impact of UK activities on biodiversity, at home and abroad?
- Technically, monitoring is targeted surveillance intended to check either whether change is occurring – i.e. the right amount of change in the right direction by a required date- or whether a particular metric remains within certain bounds so that action may be triggered in timely fashion. Much of the environmental information gathering on which the government relies is merely surveillance via repeated sampling with no specific end point or planned action attached.
- Among the UK Biodiversity Indicators, this is exemplified by the long-term reporting of woodland, wetland and sea birds. Although some conservation initiatives have resulted from these, there are no direct, auditable linkages between the collected data and what has happened or could result from changes (e.g. in relation to farming practices in different counties across the West Country). Even where data are being collected it is too often only to reveal change, usually negative, rather than to direct and evaluate steps, e.g. towards nature’s recovery.
- This lack of linkage highlights both the weakness in much of successive governments’ ‘monitoring’ efforts at all levels, and the critical need for a different approach in future. Part of the issue is that monitoring is often viewed as an optional add-on, rather than essential to guiding better outcomes, e.g. in relation to the sustainable stewardship of the use of land, water and other resources.
- As such, monitoring and other uses of environmental information have been the frequent targets of ‘savings’. As an example, past Defra cuts fell disproportionately on Natural England, with the agency’s budget cuts falling more heavily on monitoring and information provision. This has had knock-on impacts on the quality of information available to the agency, and the quality of services which it is able to provide including those for which it now charges and the extent to which these services are actually taken up. Wider impacts have included cutting of support to the National Biodiversity Network.
- It should be emphasised that this is just one obvious example to highlight the impact of the governments approach to date - and to data -, even after the UK National Ecosystem Assessment, Making Space for Nature and the State of Nature reports. The government still appears to lack environmental intelligence.
- As a result, much of government species monitoring has amounted to tracking the decline of an important but small and not wholly representative part of the UK’s biota, with no effective action of the scale that is all too clearly required being taken. This even extends to SSSIs - whether or not they contain any newts to be counted.
- Some of the existing UK Biodiversity Indicators serve little useful purpose, e.g. that for the number of publicly accessible records on the NBN Atlas. Where is the metric which shows the extent to which existing biodiversity data are being used for biodiversity decision-making, and where? How many local authorities that have neither an ecologist nor use local biodiversity data in plan formulation or assessing planning applications are there and how ready are they for biodiversity net gain?
How has the Government performed against the Aichi Biodiversity Targets and what further progress is needed?
- The Government has failed in relation to almost every target and, infamously, has sought to claim that the entirety of our National Parks should be considered as ‘protected’. Given all the promises that were made in the wake of the abject failure to achieve the Countdown 2010 targets this highlights the chasm between where we are and where we need to be. However, the main concern is the lack of meaningful measures to understand and address the weaknesses this. This must change and statutory targets adopted within local and national Environmental Improvement Plans.
Where should the four nations prioritise resources to tackle biodiversity loss?
- There will be a range of answers in response to this, most of which are likely to embrace the wise stewardship of natural resources, investment in natural capital and the value of ecosystem services on a multi-scalar basis. However, we would highlight the fact that whilst past failings have resulted from a failure to plan, more recently plans have failed partly because of top-down imposition without stakeholder buy-in or ill-coordinated bottom-up approaches. Any initiative will need to scale and communicate easily between and across different levels, whether from a particular field to the British Isles and the rest of Europe, or from a school child learning about the water cycle, frog metamorphosis or what benefits the green/blue infrastructure in their town provide for people and wildlife to the Secretary of State.
- At a more fundamental level recent plans have failed because they have been ill-informed, formulated without regard to or in spite of available evidence or despite gaping holes in evidence and without ongoing data collection and ‘proper’ monitoring being an integral part of the plan’s delivery.
- Accordingly, whatever else they do each of the four governments must invest in the environmental information infrastructure that will ensure that
- the information systems will be in place to enable different stakeholders who need or want to can have access to information of high quality to meet their purposes
- such data exists and complies with the FAIR principles and appropriate data standards
- measures are in place to collect, check, curate, and to capture new data
- adequate funding mechanisms exist to support these activities
- the necessary measures and organisations are in place to facilitate this
- There is a need for
- a costed audit of environmental data needs, gaps, provision and use, and of the means of addressing these across and beyond the breadth of the national Environmental Improvement Plan;
- a detailed information strategy to mapping out the existing and missing elements of the infrastructure required to support a world-leading national environmental information framework;
- the enabling measures required to support, link, facilitate and fund these elements to be put in place at local to national level.
- There will need to be adequate investment in establishing this information infrastructure and the organising framework in order to enable more efficient, more truly sustainable development in pursuit of local needs, national priorities and the environmental imperatives which, collectively, successive governments, business and society have yet to address – but there will firstly be the need to be a recognitions of why this is so vital.
- The environmental data sector has long advocated the benefits of harnessing information - in accordance with best practice and data standards - to facilitate digitally enabled, evidence-based planning and decision-making. For this, the right evidence needs to be findable, accessible, interoperable and reusable and used and interpreted in the right way, at the right time. The fact this has still to happen is a large part if why past efforts to halt biodiversity loss have failed
Evaluating measures to conserve and enhance biodiversity:
How should the Environmental Land Management scheme maintain and improve biodiversity?
- The critical points will be for ELMS to be shaped to deliver national priorities (once these have been identified) but targeted in accordance with everything else that will be happening in relation to the natural environment within and across Local Nature Recovery Strategy boundaries. This will also require high-resolution data initially and appropriate updating, monitoring and evaluation.
What role might alternative land use play in delivering improvements to biodiversity under the ELM scheme?
- The key role will be in by delivering public goods which contribute to Local Environmental Improvement Plans and the delivery of LNRS strategies – for which the information framework and processes outline above will be required.
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?
- What the Environment Bill presently offers is a mix of tools. Some of these are rather blunt or aren’t as well-designed as they could be, some are noticeable by their absence, e.g. environmental net gain and the UK Environmental Information Framework which ought to be in place to guide and evaluate what work should be done, where and how. Some of the tools are inherently faulty, for example National Infrastructure Projects which will inevitably impact on the NRN as well as individual LNRSs, are excluded from biodiversity net gain obligations. The handling of HS2 highlights how this undermines the whole net gain approach and raises the question of whether 10% represents an adequate uplift. Similarly, the marine environment is excluded completely. Such failings need to be remedied.
- There is also a lack of skilled practitioners to put these tools to use. This reflects attitudes of the last millennium, the lack of policing of existing obligations and the lack of resources and targeted funding mechanisms. This extends from the lack of skilled volunteers and trainers to train and coordinate wildlife recorders and citizen scientists through to the fact that more than sixty percent of local authorities – which will now have far greater responsibility in relation to safeguarding and enhancing the natural environment – lack ecological expertise. Why are biodiversity matters and the information and advice on which they depend not managed in line with what happens with the historical environment? Moreover, at national level the natural environment agencies in all four countries will only be effective if they are adequately funded – yet public spending on biodiversity has fallen to 2003 levels. Where are the measures in the Bill to address this?
- However, the main lack in the Bill is the lack of a workable plan. The 25 YEP which now forms the first national EIP amounts to a badly drawn sketch of what is proposed rather than the required detailed plan of how the different pieces will be fitted together – and the obvious gaps filled – over time – including the required data flow and supporting information systems. This is something that all departments of all governments should be working towards but the lack of a plan to integrate aspirations and actions, even across Defra, undermines confidence in the Bill.
- These failings can partially be addressed via secondary legislation but there is a need to identify how the various components will fit together to achieve the best outcomes.
- An example here is the Biodiversity Metric 2.0. This presently exists as a spreadsheet but needs to become a spatial tool which takes account of current LNRS information, opportunity areas and proposals; of the presence/proximity of priority and protected species and of the indirect impacts that will result from a development. The mapped assessments and gain proposals could then be evaluated against the LNRS map on a ‘what-if’ basis to achieve the best outcome and for determination purposes, prior to being incorporated within the LNRS map
- It should be apparent that data of a wide variety of types and the information systems to harness these will be needed to inform and evaluate decisions and their outcomes but, despite all it does put forward, the Bill fails to address this need.
How should Nature Recovery Networks be planned, funded and delivered?
- Many elements of the Environment Bill, the 25 Year Environment Plan and any new planning system will overlap considerably in relation to their data and information management needs. Local Nature Recovery Strategies will be the principle nexus for this. Based on national park, metropolitan and county boundaries, LNRSs will cover all of England without overlap. They will provide the administrative and spatial basis for targeting the new Environmental Land Management Scheme, and Biodiversity Net Gain and Environmental Net Gain offsets. Moreover, LNRS mapping of areas of existing and potential high value for biodiversity, natural capital investment and ecosystem service resilience, including opportunities improving urban green infrastructure to address nature deficiency required to produce Local Environmental Improvement Plans will also align with the mapping and information needs of Planning for the Future’s Protected, Growth and Renewal areas classifications, or some rather more implementation of these.
- There is a need to identify and safeguard not only sites and processes that are of intrinsic high value but those areas and features which serve linking or buffer roles or provide opportunities for enhancement at the landscape and ecological network level, taking account of climate change and other environmental drivers.
- Getting the national LNRS network right will therefore be vital to the successful reform of local planning delivery, to securing local community support, and to realising the aspirations of Our Green Future. LNRSs and LEIPs should inform local plans and decision making to secure the best outcomes locally, support cross-boundary working and facilitate national priority-setting, reporting and evaluation. Achieving this will depend on a number of critical components being in place for each LNRS (Box 1). Collectively, these will be part of the overall national environmental information framework.
- There is a considerable degree of variation in the profile of the existing local environmental information frameworks from one county to the next, although a local environmental record centre will be at the heart of each of these. Understanding the profile of information need, supply, use, quality assurance and support LNRS will be important for each LNRS but also in determining what collective supporting and enabling mechanisms or tools will need to be put in place. For example, an entirely new data system but one that will work with existing systems will need to be put in place to enable LERCs to support LPAs in the targeting and administration of net gain and ELMS in connection with the LNRS.
- However, there is also a need to ensure that LNRS and LEIPs have adequate weight. They cannot be plans and processes to which local authorities are simply obliged to have regard – the failure of the existing NERC Act biodiversity duty on public bodies adequately illustrates the reasons for this. The areas and targets which result from LNRSs as included within the Bill, and the LEIPs that should be added by amendment, need to have the weight of statutory obligation, and incentives for successful delivery.
- There will be a need for initial investment, e.g. to enable LNRS partnerships to map and assess habitats across their areas in accordance with the UK Hab classification, in preparation for the launch of LNRSs, BNG and ELMS, and for the information systems to support local administration, delivery and monitoring and national prioritisation and evaluation in a joined up way.
- It will also be vital to introduce effective funding mechanisms to ensure that planning applicants contribute proportionately to the provision of access to, curation and updating of information provision (and that other bodies including the national agencies, and research bodies do too) whilst ensuring that schools and members of the public are more easily able to access environmental information as data or via the whole spectrum of future Internet of Things services.
- By facilitating better environmental understanding, giving greater certainty, the resulting information systems and underpinning geospatial databases would enable major changes to the planning system: addressing perceived and real obstacles and minimising delays as well as ensuring that better evidenced local plans, development schemes, decisions and agreements result in more positive, lasting outcomes.
- Getting to this position will require several enabling measures to be put in place. The combined aspirations of Our Green Future and Planning for the Future providing ample justification for their implementation, however. Consideration should be given to how these may be integrated to best effect: increasing efficiencies; reducing overheads and providing ancillary benefits.
- Better, more intelligent use of data, information, knowledge, insight and accumulated wisdom will need to be incorporated into more effective, more enlightened EIP and LEIP delivery. Increasing data accessibility and interoperability in connection with this will have considerable added value in relation to engaging and educating us all in supporting positive action for the environment.
- Establishing an integrated environmental information framework that will work effectively across and up and down spatial scales should be a vital part of any purposeful effort to restore biodiversity and safeguard ecosystems.