BRX0183

Written evidence submitted by Stuart Coleman (personal capacity)

The following response is my informed opinion based on 30 years of working & studying in the Environmental Sector in southern England (East Anglia & the South-West). This includes:

• Approx. 14 years as a trained Ecologist / Biological Recorder; and
• Approx.10 years of submitting applications for and practically delivering agri-environment schemes across a range of land holdings, as both a nature conservation professional (for both local Wildlife Trusts, and as a private consultant), and as a contractor; and
• In recent years, working closely in partnership with farmers & landowners as a FACTS & BASIS trained Farm Adviser – specialising in resource protection & effective application (soils, nutrients, & water). 

I believe the proposed / pending departure of the UK from the EU presents both real opportunities and significant risks for biodiversity across the British Isles, but I will focus on one selected aspect of terrestrial habitats within the farmed landscape.

Summary of key point:

1. RPA / RLR land parcel designation of ‘Moorland’ needs to be reviewed, as it is currently leading to fragmentation & loss of certain key habitats and species in Cornwall.

1. Review of ‘Moorland’ Land Parcel Designation

1.1         There needs to be a regional or sub-regional review of the RPA / RLR designation as 'Moorland' of so-called ‘rough-land’ parcels in Cornwall; and a review of any future agri-environment schemes relating to this matter.

1.2         Currently there is very little financial support for managing these areas outside existing HLS schemes or new Higher-Tier Stewardship (particularly since the finish of the ESA payments - for instance, in Penwith in West Cornwall). The new Higher-Tier scheme is currently largely targeted by Natural England at significant areas of priority BAP habitat and / or designated areas such as NNR or SSSI sites. It is also limited in its scope by the recent and ongoing reduction in resources available (i.e., experienced staff time) to investigate potential sites for schemes, or to administer resulting applications.

1.3         Current Mid-Tier Stewardship has very few options available to sites classed as being above the ‘moorland line’, but that are also outside the Severely Disadvantaged Area (which in Cornwall is mainly located on and immediately surrounding Bodmin Moor) – It’s not Lowland, and it’s not Upland... so what is it..?

1.4         Effectively, Cornwall has a regionally significant quantity of low-level moorland sites; usually scattered across the landscape in small fragmented areas, but still providing stepping-stones for the movement of mobile wild species, and refuges for colonies of less mobile species. These often mosaic habitats (of mixed habitat types) do not clearly fit into the boxes of either ‘Lowland Heath’ BAP, or ‘Upland’ acid habitats, but have characteristics of both, as well as wetland / mire and wet-woodland zones. These sites are often the last remnants of a former wilder landscape, and often harbour the most diverse or valuable species resource within a largely farmed environment; many of them being given the non-statutory ‘County Wildlife Site’ (CWS) status in recognition – but offering them little protection.  Many also contain historic environment features, from early civilisation settlements and burial sites, through to industrial mining heritage.

1.5         If the owners of these smaller rough-land areas (which are often divided amongst the ownership of multiple landowners - within small farm enterprises by national standards) can not draw down funding support to manage them sympathetically, the default value for a farm business will be zero, and we shall see:

a) increasing and insidious breaking-in of the rough-land in stages (avoiding both public outcry and the attention or scope of frankly inadequate EIA regulations) to plant crops or improved-grassland for continental non-hardy livestock breeds - releasing stored carbon and contributing to soil erosion, nutrient run-off, and increased flood-risk in the process; or

b) abandonment of these areas to total coverage of thorn & gorse scrub and bracken, at the expense of more specialised and rarer species, and reducing public access and leisure possibilities;

...and in my experience both are already happening..!

Those working in the land-based environmental sector are currently fighting a rear-guard action to try and save and restore these sites. But it is becoming increasingly difficult as resources dwindle, and pressure grows for every hectare of ground to earn its keep - usually in crude yield and sellable commodity terms only.

We need to realise the true value of rough-land sites within our crowded and largely farmed landscape. Cornwall especially encompasses a wild and ancient landscape heritage and related culture. People both live in and visit its rugged charms because they value its wildness. And yet these rough-land parcels, which add corners of interest within the patchwork of crops and grass, are given little value.

Post-Brexit, we need to recognise the ecosystem services these sites provide – such as carbon storage, water storage, buffering water resources against agro-chemical and nutrient run-off;  and the inherent use of traditional low-input / low-risk farming methods on them – and also the use of innovative equipment & techniques. We should protect them, and the wildlife and historic heritage they support. They spare us the worst ravages of an increasingly volatile climate, but also offer us relaxing wild spaces to explore and enjoy. We squander them at our peril, and as a sad indictment of our modern values!

September 2016