Written Evidence submitted by RSPB Northern Ireland for the Northern Ireland Affairs Committee’s inquiry into Northern Ireland and the EU Referendum (EUN0007)

About RSPB NI: The RSPB is Europe’s largest nature conservation charity. Supported by more than 1.1 million members, we protect threatened birds and other wildlife – and the habitats which they rely upon. Locally, we are supported by more than 16,000 members and a dedicated group of volunteers and supporters.

We employ a dedicated team of staff to understand the threats facing our wildlife, manage a network of stunning nature reserves, and give our children hands-on experience of the natural world. RSPB NI invests more than £1 million annually in the protection of NI’s natural environment. Through our policy and advocacy work, we also act to influence decision-makers who have the ability and power to protect and enhance the living world for future generations.

1 Introduction:

1.1. The outcome of the referendum on EU membership could have significant implications for the RSPB's ability to fulfil its charitable objects.

The RSPB believes that comprehensive international agreements for nature conservation and the environment – together with a robust and enforceable governance framework – are essential for the achievement of the organisation’s objectives.

Nature does not respect borders and the RSPB will always promote the generic principle of effective international agreements, which ensure common environmental standards and protect our shared wildlife.

In the run-up to the Referendum, as both sides seek to clarify and present their respective visions for the future, the RSPB will challenge both the ‘in’ and ‘out’ campaigns to explain how their stance will help protect and enhance the environment. 

Therefore, while the RSPB will at no stage be telling anyone how to vote and will not be joining any official campaign, we will nonetheless play a very active role in the debate.

General comments:

1.2. The European Union has grown to have a significant impact on environmental, agricultural and fisheries policies and is now regarded as one of the most influential bodies on environmental law on the planet.

1.3. Current evidence suggests that the EU has had a positive impact through some of its environment policies, most notably through the Birds and Habitats Directives but also by setting water quality, climate change, air quality and renewable energy targets. However, significant concerns remain about some sectoral policies and environmentally harmful subsidies.

1.4. We intend to answer the questions set by the Inquiry, but have also left some answers as ‘Not applicable’ (N.A.) where they are outside our expertise or remit.

2 Questions and Answers:

• What Northern Ireland-specific issues should be considered as part of the debate on UK membership of the EU?

2.1. RSPB Northern Ireland believes that our natural environment and environmental protection is a local/regional, national and international issue of concern. We also believe that NI’s natural environment is both unique and iconic. Our wild and natural places also attract large numbers of tourists and visitors every year.

1. Our network of EU protected nature sites are crucial. The Birds Directive[[1]]  along with the Habitats Directive[[2]] form the cornerstone of EU nature conservation policy and establish the Natura 2000[[3]]  ecological network of protected areas both on land and at sea.  The designation of Special Protection Areas (SPAs) and Special Areas of Conservation (SACs) seek to ensure their long-term survival of species and habitats by safeguarding against potentially damaging development.

The Birds and Habitats Directives are the best and most effective laws we have for nature in the UK.  Furthermore their principles underpin the protection afforded to our sites of national importance (Areas of Special Scientific Interest (ASSI), Local Nature Reserves (LNR) and National Nature Reserves (NNR)). If the UK leaves the EU, the Birds and Habitats Directives will no longer mandatorily apply, leading to great uncertainty and the potential undermining of the site protection system in NI and the UK.  If a future UK Government decided to repeal the legislation that underpins the Birds and Habitats Directives in UK law, new legislation would be needed to fill this void, but such like for like replacement would be difficult to achieve.  Given Northern Ireland’s land border with the Republic of Ireland (where the Nature Directives and Natura 2000 network will remain), the need for the retention of these Directives is even stronger, as the natural environment has no regard to such man-made boundaries.

2. The requirements for Environmental Assessment[[4]] stems from both the 'Environmental Impact Assessment' – EIA Directive (Directive 2011/92/EU) for individual projects and the 'Strategic Environmental Assessment' – SEA Directive (Directive 2001/42/EC) for public plans or programmes. The Environmental Assessment process ensures that the environmental implications of decisions are taken into account before decisions are made on the project, plan or programme, with a view to reducing their environmental impact.  Hence, the Environmental Assessment Directives are vital tools for sustainable development. 
3. The UK needs to consider the implications of the financial benefits which flow from our Natura 2000 network when it is fully functioning /in favourable condition. For example, uplands with intact bog sequestering carbon, their ability to store and filter water and the protection afforded by Natura 2000 network and its requirement for condition monitoring can all assist in reducing public purse expenditure.

2.2. Agriculture also has quite a unique role in Northern Ireland – it is deeply embedded in our culture and heritage. Around 75 per cent of the Northern Irish landscape is farmed, therefore the agri sector is key to ensuring our special places and landscapes are protected for future generations. Between 1992-2007, the Common Agriculture Policy (CAP) went through various reforms which have encouraged environmental integration. Schemes such as Agri-environment within Rural Development have been helping to improve the sustainability of the wider countryside.  However, the RSPB believes that at present, the Common Agricultural Policy (CAP) is not an effective tool for addressing the environmental and sustainable food production challenges facing the UK and wider EU. The few positive elements, particularly agri-environment schemes, are dwarfed by payments and rules which incentivise unsustainable land management. The most recent reforms in 2013 were an attempt to integrate the environment further through greening payments; however the majority of farmers in Northern Ireland were able to gain greening payments with little or no change to farming practices, resulting in no net gain for the environment. The RSPB believes that to address these challenges, we need a profound change in the nature of EU policy into one guided by the principle of public money for public goods.

2.3 The Water Framework Directive (WFD) and Floods Directives (FD) have been useful drivers for improving water quality and reducing flood risk across the EU. NI has successfully implemented the architecture of both Directives through regulations; however the NI Executive has been unsuccessful at delivering the aims of the WFD due to a lack of funding, seeing only slight improvement in water quality.

2.4 In a similar vein, the aim of the European Union's ambitious Marine Strategy Framework Directive (MSFD) is to protect more effectively the marine environment across Europe. The local implementation of the MSFD is being driven by the Marine Act (Northern Ireland) 2013 which for the first time will bring forward a network of Marine Conservation Zones, helping to protect Northern Ireland’s rich marine biodiversity and contributing to the marine economy. Bringing in a network of new Marine Protected Areas (MPAs) is one way to promote a more stable future for our local marine ecosystem, a network which, if effective, could be the most economically valuable of all waters around these islands, estimated at approx. £164,000 per km2 – much more than English waters (£100,000) and almost three times as much as Scottish waters (£57,000)[[][[1]].

2.5. The potential impact of issues such as these need to be debated – particularly given the specific local context, as outlined above.  

• 3.0. Would leaving the EU have implications for the peace process?

3.1. N.A.

• 4.0. What are the potential implications for Northern Ireland’s land border with the Republic of Ireland?

4.1. As mentioned in our introductory paragraphs, nature does not respect borders. RSPB NI has been involved in a number of cross border projects, made possible (in part) by EU funding.

• 5 What are the potential implications of, and opportunities following, Brexit for Northern Ireland’s economy, including for the agriculture, manufacturing and service sectors?

5.1. With regards to the agriculture sector, the removal of EU subsidies (particularly those which assist farmers to manage their land in an environmentally sustainable manner) would be disastrous for the local industry and in turn, natural places and wildlife. In the event of an exit from the EU, uncertainty surrounding any new payments system and the allocation of funding for Environmental Farming Schemes which help address declines in biodiversity, would be a concern. In the event of an exit, clarity is required on how this system would work and what it would deliver for nature.

5.2. It is worth noting that the RSPB does not believe that the current Common Agricultural Policy (CAP) is sufficiently geared towards environmental protection or incentivising land owners and farmers

• 6 Does EU membership benefit Northern Ireland’s relationship with the ROI economically, politically and socially? 

6.1. Our work on the Halting Environmental Loss Project (HELP) has played an important role in strengthening relationships with our counterparts in Birdwatch Ireland and throughout rural communities, particularly farmers and landowners, in the border counties where the project was based. Below is a short case study which highlights the impact and performance of the HELP project:

7 The Halting Environmental Loss Project

7.1. In September 2010 the Halting Environment Loss Project (HELP) was launched, with the objective to deliver targeted cross-border habitat improvement and management for key priority bird and related non-avian species associated with farmed landscapes

7.2. In recognition of the importance and scale the project HELP received a major grant of £1.47 million from the INTEREG IVA Programme, funded by the EUs regional development fund ERDF (administered by the special EU Programmes body) the Dept of Environment for Northern Ireland and the Dept of Environment, Heritage and Local Government in the Republic of Ireland.  Reflecting the geographical range of the project, contributory funding was also provided by RSPB Scotland.  Project lead partners are RSPB NI, RSPB Scotland and BirdWatch Ireland.  Critical to the success of the project was the development of close working partnerships with famers and statutory agencies within the project areas.

7.3. Based on their declining and vulnerable conservation status, the key avian species were breeding waders (lapwing, curlew, snipe and redshank) in NI and the RoI, and corncrake and chough in Scotland.  Non-avian related target species include Irish lady’s tresses orchid, northern colletes bee, slender scotch burnet moth and Irish damselfly.

7.4. The aims of HELP had the support of farming communities and rural economies at their heart:

1. To maintain and expand the population and range of breeding waders, corncrake and chough in key areas for these species across NI, Scotland and RoI.
2. Maintain and encourage expansion of non-avian UKBAP species.
3. Champion successful conservation management techniques to promote the sustainable recovery of UKBAP wetland species across border counties in NI and RoI.
4. Information sharing to disseminate successful conservation practices and best-practice farming methods.
5. Promote wildlife friendly tourism and biodiversity’s critical role in providing a sustainable and diversifying source of income generation for wider rural communities.
6. Boost long-term awareness and appreciation for biodiversity.

7.5. Through HELP we worked with over 500 farmers across the three countries, the success of which was seen in the increase of species on the ground, and landowners now fully equipped with the knowledge on how to manage their land for priority species. Information we learnt through this project has helped to shape the new Agri-environment/Environmental Farming Scheme in both NI and ROI.

7.6. RSPB NI, RSPB Scotland and BirdWatch Ireland have recently submitted a new bid to the INTERREG programme, to build on the success of HELP. We will hear if we have been successful at the Stage one in March 2016.

• 8 What impact would the loss of EU funds have for Northern Ireland, and how could these be compensated by the UK Government from the monies that would otherwise have been paid to the EU?

8.1. One small example is funding for the Environmental Farming Scheme (EU funded) which is c£100 million between now and 2020. Loss of this funding, with no certainty about what would replace it, would be very worrying and add a significant amount of stress to an already under pressure agriculture sector.  

8.2. RSPB NI believes that the natural environment has been consistently under-resourced by national governments and this has led to nature policy being low on the political agenda. We would be concerned that any exit from the European Union would exacerbate this situation when it comes to deciding financial priorities.

• 9 What opportunities could exist for the UK Government to increase spending and to reduce taxes in Northern Ireland following Brexit?

9.1. It is difficult to comment as there is no clarity about how spending might be rearranged in the event of ‘Brexit’.

• 10 To what extent have regulations and directives issued by the EU affected business in Northern Ireland? 

10.1. The Nature Directives (The Birds Directive and the Habitats Directives) are hugely important drivers to help halt biodiversity loss. It would be to the detriment of those economic sectors which rely directly on a thriving natural environment. In Europe, around 4.4 million jobs and €405 billion in annual turnover are directly dependent on healthy ecosystems[1].

10.2. RSPB NI believes that, in the main, EU environmental directives have been good for business, as they provided clarity, transparency and a ‘level playing field for businesses. We believe that initial concerns are eventually replaced by a greater understanding and smoother outcomes, as better spatial planning, location or design leads to the integration of natural environment objectives in business planning. Familiarity with the Directives facilitates constructive results.

• 11 Does leaving the EU have implications for the energy market in Northern Ireland?

11.1. Leaving the European Union could have significant implications for the energy market in Northern Ireland. For example, it could result in decreased interconnectivity to Europe which may affect security of supply, and potentially lower the amount of renewable electricity that is imported to Northern Ireland’s grid. It could also lead to a reduction in low carbon investment into NI by multinational companies, acting as a brake on the transition to a more sustainable energy system. This could have serious implications for NI’s greenhouse gas emissions and efforts to mitigate climate change. In the long-term, climate change is one of the greatest threats to wildlife – with up to one in six species at risk of extinction under current levels of warming.[2]

11.2. Key environmental safeguards which protect species and habitats from energy infrastructure development are also the result of European legislation. For example, the Birds and Habitats Directives (the Nature Directives) protect NI’s most important wildlife sites from potentially damaging development, and the Strategic Environmental Assessment (SEA) and Environmental Impact Assessment (EIA) Directives help to ensure the appropriate siting, design and management of energy projects. A more integrated and interconnected energy system with other EU member states would enable projects to be strategically sited in the least environmentally sensitive locations.

11.3. Finally, it is unclear which renewable energy and climate targets would remain in place for NI in the case of an exit from the European Union. NI currently has targets under the Renewable Energy Directive (RED) to source 40% of electricity consumption and 10% of heat consumption from renewable sources by 2020.[3] The RED has acted as a key driver in the uptake of renewable energy across Member States, helping to drive down emissions and decarbonise energy supplies. Withdrawal from the EU would also mean that the UK (and by extension NI) would not have a specific international climate target under the United Nations Framework Convention on Climate Change (UNFCC), as these targets were negotiated as part of the EU bloc. The lack of clear long-term targets and the increased certainty that these provide could mean that the Northern Ireland energy market is less able to deliver against key decarbonisation objectives, and therefore protect wildlife and habitats, as well as people and agriculture, from the risks posed by climate change.

• 12 What would be the potential effects of leaving the EU on capital and migrant labour flows in and out of Northern Ireland?

12.1. N.A

17 February 2016