National Association for Areas of Outstanding Natural Beauty (NAAONB) – Written evidence (NSD0021)


This response is from the National Association for Areas of Outstanding Natural Beauty (NAAONB) - a charity that promotes the conservation and enhancement of natural beauty, and advances the education, understanding and appreciation of the public in relation to this, in and around Areas of Outstanding Natural Beauty (AONBs), other Protected Areas, and those landscapes for which designation might be pursued. The NAAONB supports and connects the AONB partnerships and organisations covering the 34 AONBs in England, as well as those in Wales and Northern Ireland. AONB Partnerships and teams locally work to manage AONBs covering 18% of our countryside.


Through statutory Management Plans, partnerships with broad representation and small specialist staff teams with local knowledge, AONB organisations collectively are an important deliverer of nature-based solutions and integrated land management. We welcome the enquiry on this important topic, and our response focuses on selected questions where our experience lies.


3. What frameworks already exist for the regulation and financing of nature-based solutions?

         Are there good examples of nature-based solutions already being undertaken in the UK or elsewhere, and what can we learn from them?


Case study - northern upland peat restoration

Since 2006, the North Pennines AONB team has led the restoration of 35,000ha of drained or bare/eroding peatland – an area three times the size of Newcastle. Additionally, since 2010, the Forest of Bowland AONB unit has managed and delivered the restoration of over 4,000ha. of degraded peatland.


The work involves re-wetting large areas of blanket bog through blocking grips (drainage ditches) and gullies, and revegetating bare and eroding peat by managing water flow, spreading seed-rich heather brash, cottongrass planting and Sphagnum inoculation. This benefits blanket bog vegetation communities and supports a suite of upland bird species including curlew, golden plover and dunlin.


More recently, AONB Partnerships have been at the heart of the developing peatland restoration initiative, the Great North Bog ( This is a landscape-scale approach to restoration across nearly 7,000 km2 of upland peat in the Protected Landscapes of northern England, which currently store 400 million tonnes of carbon. Damaged peat in the Great North Bog releases 3.7 million tonnes of carbon annually. The programme aims to develop a working partnership to deliver a 20-year funding, restoration and conservation plan to make a significant contribution to the UK’s climate and carbon sequestration targets.


Action for peatlands can improve carbon sequestration and storage, but also since the condition of many peatlands is poor, it is vital to actually reducing current emissions. 6% of UK carbon emissions come from damaged peatlands (comparable with the 7% of emissions which come from air travel). Restored and well-managed peatland stores and sequesters millions of tonnes of carbon every year, allowing it to then sequester more carbon into the future. Healthy peatland also plays a vital role in flood mitigation and reducing both sediment load and water colour in our rivers.


Other examples are available at:


Many of these initiatives have focussed primarily on nature recovery, with additional climate benefits. As data on carbon sequestration becomes more available and better understood, this is becoming a stronger factor in projects and land management decisions. It is important however that nature-based climate solutions do integrate well with nature recovery and action to address the parallel biodiversity crisis. Nature-based solutions at an extreme end of the spectrum could become forms of geo/bio-engineering focused solely on carbon which could be quite harmful to nature. Such measures are likely to be applied on less agriculturally productive areas of land, and these areas are effectively the fragmented remaining vestiges of good quality habitat we have, and the basis of a Nature Recovery Network which we must build and develop. Nature-based solutions for climate must support and not undermine this. In many cases there is a win-win with the best carbon outcome coming from habitats in the best condition for nature, but where this is not the case a balance will be needed.


Tree cover

Many AONBs can accommodate or benefit from increased tree cover but the ‘scramble’ for tree planting could result in harm to other habitats and some landscape settings. Tree planting schemes in AONBs should be sensitively designed (right tree, right place principle), with a high proportion of native trees and shrubs suitable to the location and strong consideration of natural regeneration and promoting natural processes. The consent and grant system through the Forestry Commission is key to ensuring this quality. We are still seeing tree planting occasionally being supported by FC on peatland sites despite comments on this, which is disappointing.


The myth of offsetting

A risk associated with nature-based solutions is that organisations (or individuals) seek to buy their way to claims of carbon-neutral operations by modest emissions reductions and then offsetting the rest, which usually involves nature-based solutions – often tree planting. This mathematical exercise may appear to deliver a carbon-neutral company, but when the UK’s (or global) carbon budgets are looked at, it is clear that net zero can only be achieved if emissions reductions are reduced by 90+%. There simply isn’t enough offsetting capacity available through nature-based solutions for all the companies and people who might want this easy route. Many carbon neutral claims do not therefore stack up as part of a credible overall net zero plan. Trading standard regulations around ‘carbon neutral’ claims will surely be needed to address this problem, as it leads companies to ease off their action on emissions reduction and can also drive poor land-use changes in areas of countryside selected for offsetting schemes. Government schemes seeking to bring in new financing models should ensure to avoid these pitfalls.


4. Who are the key stakeholders for the implementation of nature-based solutions in the UK? How can stakeholders’ expertise and concerns inform the incentives and requirements for implementing nature-based solutions?

         How can farmers (including tenant farmers) and land managers be supported in their deployment of nature-based solutions by policy and legislative frameworks?


Discussion on land management for climate benefits has increased significantly in recent years, and many farmers are keen. The policy and funding landscape is however a complex one, seeking to incentivise and balance many different objectives. The integration of nature-based climate action into the Environmental Land Management (ELM) schemes will be important, and in the shorter term, the new Farming in Protected Landscapes programme provides a good additional mechanism within AONBs and National Parks. There are down-sides however to the proliferation of government schemes of a short-term nature which may be introduced at relatively short notice and with short lead-in or application periods. A longer term approach to public sector funding (which can be adapted over time) would help ease these limitations.


As with other environmental goals, while funding and incentives are important, minimum standards set in legislation are also important and could probably be extended to improve land management for climate. Not least, this helps to prevent the scenario where publicly funded initiatives on one part of a holding may be undermined by action going in other directions elsewhere on the holding.


The experience from many generations of farm environmental schemes is that the provision of good practical advice from trusted and knowledgeable local advisers is a strong factor for success, in addition to capital funding. Continuity of relationships with advisers helps a lot, and recent experience through Farming in Protected Landscapes and Water Environment Grant projects suggests that there is an inadequate supply nationally of suitably experienced and knowledgeable advisers. This bottleneck should be addressed by structured action to build capacity in the sector and improve adviser career paths, with experience on the ground being just as important as training and qualifications.


         Are there examples of projects which have engaged with stakeholders and local communities to implement nature-based solutions successfully, and what can we learn from them?


Case Study - Connecting the Culm (Blackdown Hills AONB)

Connecting the Culm is a catchment based partnership project working to tackle some significant challenges faced by the River Culm in Devon, running from January 2019 until December 2022. It is part of a larger Co-Adapt (climate change adaptation through co-creation) project, part funded by EU Interreg 2 Seas. The partnership project aims to:


It will do this by:

Co-Adapt: Climate adaptation through co-creation | 2 Mers Seas Zeeën (


5. How should implementation of nature-based solutions be integrated with other government policies for landscapes and seascapes, for example, agricultural, forestry, and land-use planning policies?

         How could nature-based solutions implementation contribute to the UK’s goals surrounding biodiversity, the preservation of nature, and adaptation to climate change?


As set out above, the integration of nature-based climate solutions with actions for nature recovery is vital. Land (and water) delivers many benefits and services and must not be thought of just in terms of carbon, or there could be a potential risk of harm to nature. AONB Management Plans and component Nature Recovery Plans provide means of helping this integration within AONBs, and Local Nature Recovery Strategies should be encouraged to do the same.


The available scientific evidence on carbon sequestration from different habitats is relatively limited, and the ranges in figures quoted are often wide, due to the variability of natural factors. The Natural England report from 2012 has recently been updated which is very valuable, but this is a dense and long scientific report. New material which made aspects of this dataset more accessible to farmers and land managers would be very beneficial e.g. spreadsheet toolkits, summary and visual communication of key points, etc. This material should be set out as guidance for improving carbon sequestration and storage while also optimising the biodiversity value of land.


On tree planting the systems and definitions employed can be a limitation, especially standard planting densities which don’t recognise well approaches such as agro-forestry and wood pasture, which can deliver carbon benefits while retaining other habitat quality or land productivity.


The Forest of Bowland AONB Climate Change Adaptation Plan worked out which habitats were most vulnerable to the effects of climate change, such as peatlands, upland hay meadow and wet woodland and sought to drive action to restore their condition to create greater resilience on these habitats.


         Which ongoing governmental plans, policies, and strategies are relevant to nature-based solutions, and can they be better coordinated? For example, are the Nature for Climate Fund and associated targets for peatland and forestry restoration designed so as to support nature-based solutions?


The Nature for Climate Peatland Fund is an improvement on previous schemes, as revenue costs are included as well as capital. The Discovery grant stage is also welcome but necessary feasibility work, but the 3 year duration of the scheme means that implementation time after a Discovery grant will be short. The scheme could improved by allowing more time for partners to come together and to prepare applications.


We await eagerly further action from government to implement the recommendations of the Glover Review of designated landscapes, including strengthening the status and resourcing of AONB organisations, and strengthening the duty of regard on public bodies.


For nature-based solutions to achieve their full potential requires upskilling, culture shift and join up in all relevant areas of government including not only the Defra family and arms length bodies, but support for engaging communities through MCHLG, planning policy such as NPPF, etc. There seem to be approaches at odds with nature-based solutions within parts of Environment Agency and also from different government departments such as DTI, DfT.


Pilots and innovation provide a valuable role for government e.g. Flood and Coastal Resilience Innovation programme (FCRIP) - we need more programmes like this in order to test how to do things differently and change future policies to mainstream nature based solutions, for example for flood risk. One of the 25 successful FCRIP projects is in Devon, led by Devon County Council, that includes the Blackdown Hills AONB as a delivery partner and majors on nature based solutions in rapid response type catchments Flood and Coastal Resilience Innovation Programme (FCRIP) - Flood Risk Management (



Yes, and incentives should take account of full cost (to the land manager) of implementation/ management. They also need the right advice and support for land managers that is of value and can be sustained (keeping up to date with latest science).


Environmental Land Management benefits delivered should be stackable e.g. if a land manager on an area of land is delivering in-combination benefits (e.g. biodiversity plus flood mitigation plus water quality plus climate) there should be an element of reward for each.


10 September 2021