BD01 Dr Jonathan Davies

Senedd Cymru | Welsh Parliament

Pwyllgor Newid Hinsawdd, yr Amgylchedd a Seilwaith | Climate Change, Environment, and Infrastructure Committee

Biodiversity and the nature emergency | Bioamrywiaeth a’r argyfwng natur

Ymateb gan Dr Jonathan Davies, Bannau Brycheiniog– ar ran y Tri Awdurdod Parc Cenedlaethol yng Nghymru | Evidence from Dr Jonathan Davies, Bannau Brycheiniog- on behalf of the Three National Park Authorities in Wales’

Enhancing the role of designated Landscapes in implementing the COP15 biodiversity agreement in Wales

Paper for the Climate Change, Environment, and Infrastructure Committee.

Prepared by Jonathan Davies, Bannau Brycheiniog, based on consultation between the 3 NPs.

26/05/2023

The Kunming-Montreal Global Biodiversity Framework (GBF), adopted in December 2022 at the Convention on Biological Diversity’s COP15, includes 23 targets designed to address the global biodiversity crisis. The decision includes targets for effective conservation and management of at least 30% of the world’s lands, inland waters, coastal areas and oceans, with emphasis on areas of particular importance for biodiversity and ecosystem functioning and services. The GBF prioritizes ecologically-representative, well-connected and equitably-governed systems of protected areas and other effective area-based conservation, recognizing indigenous and traditional territories and practices. The GBF targets restoration (completed or underway) on at least 30% of degraded terrestrial, inland waters, and coastal and marine ecosystems, reducing to near zero the loss of areas of high biodiversity importance, including ecosystems of high ecological integrity, cutting global food waste and reducing by half both excess nutrients and the overall risk posed by pesticides and highly hazardous chemicals.

Designated Landscapes (DLs) can play a significant role in delivery of these targets in Wales. The DLs can demonstrate an existing contribution to some of the Targets, but with appropriate support that contribution can be significantly increased. The recommendations in this paper align with the recommendations from the Welsh Government Biodiversity Deep Dive group of experts, which identified key themes and recommendations for specific actions. Those recommendations included: transforming our protected sites series so that it is better, bigger, and more effectively connected; creating a framework to recognise Nature Recovery Exemplar Areas and Other Effective Area-based Conservation Measures (OECMs) that deliver biodiversity outcomes; unlocking the potential of DLs to deliver more for nature; continuing to reform land and marine management and planning (including spatial) to deliver more for both protected sites and wider land / seascapes; building a strong foundation for future delivery through capacity building, behaviour change, awareness raising and skills development; unlocking private investment to deliver for nature at far greater scale and pace; and developing and adapting monitoring and evidence frameworks to measure progress towards the 30 by 30 target and guide prioritisation of action.

Ear mark funds for leveraging nature recovery in DLs, including SFS and other delivery mechanisms.

Farming, including grazing, uses the largest share of land in most DLs and for the DLs to add value in addressing the biodiversity crisis, the contribution of farming and grazing to nature recovery within those landscapes must be above the national average. This requires higher adoption of biodiversity-friendly measures under the Sustainable farming Scheme than outside the DLs. Welsh Government should consider options for giving farms inside DLs improved access to the Sustainable Farming Scheme, for example by boosting their score for being within a DL.

DLs are ideally situated to identify the highest value options under the SFS for nature recovery and to promote adoption by farmers, through individual and collaborative actions. Welsh Government can learn from the experience of Defra in implementing “Farming in Protected Landscapes” in England and develop a comparable instrument to be made available in advance of the launch of the SFS. The purpose of such an instrument should be two-fold: promoting participation in the SFS and delivering a higher level of nature recovery outcomes on farms that exceeds the ambition of the SFS.

The SFS dwarfs the amount of funding that a Designated Landscape can use: SLSP, NRW’s Strategic Allocation Fund, and the Nature Network Fund are not of the same order of magnitude as an agri-environment scheme. DLs use precious resources in sourcing and administering new forms of grant funding or developing schemes in response to WG-funded and NRW-funded schemes. Public money would be saved by allocating this funding directly to the DLs, who have demonstrated their delivery capacity and expertise. DLs would also benefit from quicker outlining of SMS priorities & options and values.

Identify long term funding mechanisms for projects to be implemented beyond typical 2-3yr windows, including mechanisms for at least 10-year funding for some NR issues.

Nature recovery projects depend on the actions and goodwill of landowners and managers, requiring a painstaking process of collaboration, negotiation and mediation. These processes can be played by DLs, but they require stable funding in the long term to build and sustain teams fit for purpose. DL staff may lack the skills and experience and would benefit from traineeships or sponsored education to develop capacities. DLs can play a lead role in building relationships, convening partnerships, fostering collaboration, and enabling actors to implement large scale nature recovery. These roles require dedicated nature recovery units with adequate resources to catalyse action throughout DLs on a meaningful spatial scale.

Strengthen capacity of DLs for attracting private investment for large scale nature recovery

Substantial private investment is needed to achieve biodiversity goals and DLs have limited capacity to engage private investors in partnerships for long term impact. Welsh Government should provide DLs with additional capacity and access to technical expertise for private sector engagement and innovation in support of nature recovery. DLs are an ideal location to develop innovative private sector partnerships that aggregate investments into the multiple ecosystem services generated by nature recovery, and that aggregate the supply of those ecosystem services through collaborative action in target landscapes. DLs can also lead the way in developing results-based approaches that promote biodiversity restoration on farms.

Strengthen capacity in DLs for nature recovery planning and implementation.

WG should strengthen human resources and staff capacities to use tools for nature recovery planning, such as the CURVE maps, Resilient Ecological Networks, Landscape Character and Condition Assessment and others. Strategic planning of nature recovery should be made integral to the development of Nature Recovery Exemplar Areas and Other Effective Area-Based Conservation Measures. The use of strategic planning as a tool for mobilising and collaboration with other actors in DLs, including farmers and other agriculture actors, should be strengthened. Improved use of nature recovery planning will complement existing Nature Recovery Action Plans, strengthen collaboration, and will help prioritise scarce resources.

Reduce the bureaucratic process around consenting and funding for nature positive works in, and for active management of, designated sites.

DLs have a core mandate for Nature Recovery and should be given greater freedom and responsibility for implementing appropriate works on designated sites, including marine designated sites. DLs should be adequately resourced to actively manage designated sites in the character for which they were designated. Simplified mechanisms are needed to allow implementation of management actions for which sites were originally designated, such as fast-tracked license application, reduced fees, or waived consents. This could go beyond designated sites to promote the "joined up, and “bigger and better" thinking. It could also include positive actions beyond what a site was designated for (e.g. natural flood management actions).

We are hopeful that the Interim Environmental Protection Assessor’s review of designated sites will recommend that Natural Resources Wales establishes long-term consents and assents with ‘safe pair of hands organisations’ such as DL authorities, freeing up NRW to focus instead on more intractable problems and owner-occupiers.  We would hope to develop long-term concordats with organisations such as NRW, National Trust, Dwr Cymru Welsh Water and other relevant NGOs too.

Simplify funding operations within NRW to facilitate their staff to be able to contract works OR to allow trusted partners to deliver on their behalf.

As mentioned above, DLs and NRW have a shared mandate for Nature Recovery, and DLs should be a partner of choice for NRW to enhance delivery of nature recovery.

Monitor progress towards nature recovery in DLs, for example connecting with established initiatives.

Welsh Government and NRW have generated significant environmental data at the national level but monitoring systems do not currently match the needs of the DLs. Furthermore, condition assessments of designated sites are out of date, creating a barrier to achieving favourable conservation status as a contribution towards 30by30. Earth observation data from Living Wales, combined with surveys carried out under Erammp can provide important information about the state and trends of DLs. It is recommended to use these established data sets, and others, to evaluate environmental trends in nature recovery in the DLs, but data must be accessible to DL's in a timely manner. It is further recommended to address gaps in sampling that undermine analysis in the DLs. Established survey points in DLs could provide insights into trends in habitat condition, species populations, and ecosystem functions and services and will be useful to tracking progress up to 2030. Addition of a limited number of new survey points in DLs can strengthen this analysis and give greater confidence in the performance of the DLs in achieving Nature recovery targets. Welsh Government can enable this by mandating the DLs s and other Public Bodies to work on environmental monitoring across the environment and agriculture sectors.

Welsh Government should also support skills development of DLs for survey and monitoring. DLs have access to a growing array of useful datasets, for example the Environmental Change Network sites, county and highways weather stations, river gauging stations, and other ‘big data’ sources and should be enabled to capture, analyse and transfer the knowledge from these data to understand the changing trends in the DL in response to climate change and nature decline. Further support is recommended for training, mentoring and emergence of future generations of county wildlife recorders and naturalists who form the backbone of nature conservation in Wales and the UK.

Identify and tackle national-level and local-level policy clashes in both terrestrial and marine environments.

At times policies clash and give conflicting direction. Examples include conflicts between local authority grass mowing policies and nature recovery / climate change policies, Important Curlew Area boundaries overlapping with National Development Framework maps for wind farm development, monitoring of bat fatalities at existing wind turbines to better inform wind energy development decisions, forestry removal off deep peat, and policies against simple grazing infrastructure despite peat/biodiversity and carbon targets. These clashes also exist in planning, risk management authority policy and highways management. At present those clashes must be negotiated on a case by case and authority by authority basis. Conducting this work nationally would free up resources and help drive rapid and widespread action for nature. Welsh Government should conduct a national policy review to identify clashes and to provide direction on the hierarchy of policies at both national and local level.

Welsh Government is also recommended to review the effectiveness of implementation of key legislation for biodiversity conservation, such as the Town & Country Planning Act (1990), and Environmental Impact Assessment (Agriculture) (Wales) Regs.

Improve cost benefit analysis and evaluate investment pathways related to sustainable land and water management (e.g. flood and drought remediation).

Many of the highest value actions for Nature Recovery generate multiple outcomes, including biodiversity conservation, improved water quality, climate change mitigation, and climate change adaptation, including flood and drought mitigation. Nature recovery generates health and well-being benefits with significant economic benefit (reducing long term health conditions, improved mental health and well-being, and reduction in pressure on healthcare services resources / budgets etc). Improved valuation of these benefits in relation to their cost will provide valuable evidence that can be used to mobilize private investment. With increased public support, including co-convening of investment partnerships, DLs can help to increasing the flow of finance for nature recovery and ecosystem rehabilitation. This is consistent with the concept of Nature based Solutions pro­moted by the UK government at COP26.

Streamline NRW procurement and licensing processes for working with Land Agents

Simplifying these processes would allow DLs, as the Local Authority, to work more efficiently on their own land. This will allow resources to be utilised more effectively and efficiently on ecosystem and biodiversity restoration at scale.