Natural Environment and Rural Communities Bill

I am grateful to the noble Lord, Lord Cameron, for having introduced Amendment No. 132. I appreciate the principal objectives behind the common standards as a means of assessing and monitoring the condition of designated sites. Some such mechanism is advisable if the statutory agencies are to carry out their functions effectively. However, from my experience in such matters, which is based entirely in the uplands, the system appears far from satisfactory. One of the fundamental difficulties rests in the lack of consultation between JNCC, Natural England as it will be, or English Nature as it has been, and land managers. We seem to have foisted on us what I can describe only as rather arbitrary condition assessments. All those who are responsible for the management of such sites have their views not entirely ignored but certainly pushed to one side. The lack of appreciation of practical management is the real problem. The most common complaint is that the term ““favourable condition”” too often relates to what I may describe as a past point in the ecological development of the site. That often seems to have little bearing on the purpose for which it is being used at the moment. That seems quite unrealistic, especially when such an objective is unlikely to be met with a realistic timescale and a site has historically been managed in ways inconsistent with the JNCC’s objectives. I am bound to say that some of the criticism that I have read makes me wonder why the site was designated in the first place. In attempts to try to enhance some species that may have been present at some moment in the deep and distant past, such as some rare bryophyte, some current conservation gains could be lost that depend on the present management structure. In the uplands, the guidance suggests that favourable conditions should be assessed by reference to their original historic state. We could be talking about the Ice Age. Sometimes, I cannot see the point. There must be a more realistic approach to how those condition assessments are carried out. Furthermore, it is clear from comments that I have read and conversations that I have had that there is dispute—the noble Lord, Lord Cameron, referred to this—about many of the conditional assessments for the lack of clear science, which should be a prerequisite for any material change in the management structure of the site. I cite an independent ecologist who, quite recently, when commenting on the condition assessment of an area on the North York Moors National Park, said:"““The way that results are reported can cause misunderstanding and damage relationships between moorland managers and conservation agencies. Many managers are proud of their moors and believe that they have been managed well for conservation, as well as for commercial purposes. It would be much better if the results could be presented in a more accurate light, which reflects the degree of failure, e.g. eight out of 10, rather than just ‘fail’””." She has a very good point. That is particularly important when vegetation condition may be a legacy of circumstances outwith the manager’s control—for example, past air pollution or a severe wildfire created inadvertently by a visitor several decades ago. This is clearly just a probing amendment. I hope that the Minister will appreciate the real concerns expressed by managers of upland SSSIs. As I said, I can speak only for uplands SSSIs, but I am sure that similar situations occur in other parts of the country. I hope that we can try to instigate a more realistic approach to the assessment criteria, with greater co-operation and dialogue from the beginning. It is important for JNCC, English Nature and the Government to appreciate that the manager has just as much to offer as a scientist and should be consulted more often. I know that the Minister will agree with me. As the noble Lord said, we must make sure that we apply rigorous science in these conditions.