LBAP-formal-comments-9August2012

BRIGHTON AND HOVE’S WILDLIFE FORUM

FORMAL CONSULTATION on the Local Biodiversity Action Plan (LBAP) for Brighton and Hove

Formal representation – Sent to BHCC 9 August 2012

Draft B&HCC Local Biodiversity Action Plan – 9 August 2012

Comments by Brighton and Hove’s Wildlife Forum

Summary

“This is a detailed document which is not easy for people to follow. We are anxious that the document is easy to use thereby being of value to specialists and non-specialists alike. Therefore, it is difficult to see how useful it will be in this style, apart from possibly some specialised areas such as Development Planning; where the LBAP will provide a key strategic document to help set the direction of the LDF in relation to balancing the natural environment ‘strand’ in sustainable development with the economic and social strands. In terms of promoting biodiversity the LBAP needs to be progressed as ‘a process’ to engage all local stakeholders.

The draft Local Biodiversity Action Plan (dLBAP) needs full consultation with adequate circulation to encourage involvement of the population at large. This should include local businesses, universities, and all those residents and groups who are stakeholders in local biodiversity actions. The dearth of responses on the Council’s own City Wildlife Forum Local BAP page rather proves the point that there needs to be a greater commitment from the Council to involve people. This is of concern, as this is a vital subject for the City and its people, yet it is not being given the promotion and easy access needed. Wildlife and access to nature has been shown to be a prime concern of people, so the dLBAP consultation needs to respect and respond to this. That will make it a more powerful plan for action.

Brighton and Hove’s Wildlife Forum (BHWF) sees the Local Biodiversity Action Plan as the key foundation stone for success in the application to UNESCO for the Biosphere Reserve Project. A poor Plan, or one not given any real status, will weaken the application and significantly diminish the chances of success.

It is essential that the City Council takes on board its formal DUTY to promote biodiversity, which requires an agreed written plan to ensure priority objectives and actions are in place to help fulfil this DUTY.

B&HCC Consultation Process

BHWF asked as members of the City Sustainability Partnership over a year ago for the Consultation to be very wide and with a request that a Summary or Quick Reference Guide as produced for the recent City Plan Consultation appropriate to the wider population was also provided. This has not been actioned and the Consultation referred to at the CSP meeting of as long ago as 6 June 2011 with an extended consultation period to allow for the “long summer break” of 2011 never proceeded and a very limited “smaller scale and more focused consultation process” was proposed at the CSP meeting on 14th May 2012. Whilst common sense prevailed with the current Consultation being open to all, BHWF notes that there appears to have been no effort to engage with a wider audience. BHWF sees this as a clear demonstration of the Council’s lack of real commitment to promoting biodiversity.

What would BHWF expect to see?

The LBAP should clearly follow national guidelines. A main element in preparing the LBAP is to include people and groups which are interested or can influence local wildlife. Successful collaboration will provide a strong basis for progressing the actions later which people agree with. The England Biodiversity Strategy (EBS) which was updated in August 2011 provides recommendations for engaging with local people.

Its four Themes were stated as:-

1) Theme 1. A more integrated large-scale approach to conservation on land and at sea;

2) Theme 2. Putting people at the heart of biodiversity policy;

3) Theme 3. Reducing environmental pressures;

4) Theme 4. Improving our knowledge.

We do not feel that the dLBAP adequately addresses these Themes.

To put into simple language, we would stress the following for what we would expect for our LBAP:-

a) Clear how participants and stakeholders are included in development of the LBAP, action and monitoring;

b) Simple for people to provide an input;

c) It should be inspiring. Many people will sense a connection with the ‘intrinsic value’ of nature. It can state there is beauty in nature which sustains the human spirit. It is from nature that humans first appeared and we can learn to reconnect with local nature if it is given space to flourish;

d) Document that is easy to access;

e) Document that is clearly laid out;

f) Linked to the England Biodiversity Strategy and Delivery Plan, Sussex LNP and Biodiversity Partnership guidelines, such as the Sussex BAP Objectives and Targets;

g) Clear how final Objectives and Targets are to be agreed;

h) Clear who has primary responsibility to deliver the detailed Objectives;

i) Clear who will monitor progress;

j) Has a ‘reporting mechanism’ to record progress/failures;

k) Can be reviewed, updated and improved.

This current draft fails to meet these criteria.

More detailed comments on the Draft LBAP

We do not have the resources as a voluntary organisation to comment on every part in detail, but we make the following comments as being indicative of our thoughts.

The Summary

It is stated that “the successful development of this draft LBAP depends on the active participation of all sectors of society, including the business, public and voluntary sectors. Local community involvement is particularly important …” (para 4, page 2). Exactly our point! But, this is not a document that is easily accessed and there does not seem to have been any attempt to reach the general public, instead relying on interested parties to try and find it.

It should be inspiring! Biodiversity matters profoundly to us all, yet this appears to be ‘just another document’ in its current drafting. A way to meet a target set within the local authority, rather than promoting biodiversity. The LBAP should be both inspiring and a call for action to conserve and improve our shared local biodiversity inheritance. This links to childhood.

“Our love for nature is expressed in childhood (‘Biophilia’ is EO Wilson’s term, 2008). Stories such as the princess kissing an ugly frog to suddenly gain the affection of a handsome prince. This apparently instinctive attraction to nature then becomes stifled a few years later as teenagers learn about cars, houses, tuition fees and more immediate distractions. But whilst mortgages, loan repayments and tax discs make unpleasant demands, we can find abundant joy and beauty in nature”.

We suggest this can be included in the LBAP by writing:

“Reconnecting with nature can give us endless curiosity; can be emotionally pleasurable; and ultimately spiritually fulfilling. These three elements provide the core meaning to our life. Sharing in nature and valuing nature will always improve life.”

Plain English, wildlife-orientated language, presented in a way that everyone can access and understand should be a key goal, especially in Brighton and Hove, where its citizens have voted in a Green MP and a Green administration for the City Council. The more it can be used as an everyday resource the more valuable it will be.

There is a fundamental philosophical point concerning the definition of biodiversity and the application in this LBAP. The early rhetoric refers to the downland around our city; the greenspace within it; and the coast. However, this is then qualified by narrowing interest to “the species and the habitats of particular importance in Brighton and Hove. These have been identified by taking account of the nationally important species and habitats …”.(para 3, page 2). Turning to improve our contact with all nature, as well as the national rarities and habitats that are found in and around the city, it is vital that there is recognition of the basic need for “common” wildlife to thrive and be within reach of residents and visitors. It is all habitats whether they be the downland; greenspace including open land; and our front and back gardens; the coast; or our buildings. They all form habitats and proper planning can further enhance their value for nature. This narrowing of our LBAP would also appear to conflict with the broader concept of the Biosphere Reserve Project.

Paragraph 5 goes some way to the right goal, with the aim that biodiversity will be “fully integrated into decision-making … local communities fully involved … common understanding … habitats and species successfully conserved …”, which needs to embrace the above points to make it effective. The five principles are broadly supported, but as this is followed by the point about 115 species of national importance, it is necessary to note the more common species and the everyday wildlife contact of people.

The Introduction (Part 1)

This provides the background or context to the action plan, detailing both the generalities about biodiversity and specifics of Brighton and Hove. It could be shorter, so one can ‘cut to the chase’ more quickly, to access the meat of the action plan. For example, much of the history and justification for biodiversity planning could be put in an appendix. These would be a background resource and would leave the bulk of the text to be about the City, which would make it an easier and a more relevant read. Altogether a more useful document, which people would find of benefit on a day to day basis, thereby bringing biodiversity to life.

Species (Part 2)

To ease into this section, it would be preferable to group the species, providing an introduction that covered the main animal and plant types. This could note the need for conservation of even our more common species (e.g. lepidoptera per se, before honing in on particular species).

Habitats (Part 3)

Rather than a list of habitats arranged alphabetically, it would be better to present them by similar type, i.e. all the marine and coastal habitats, urban habitats, the farmland and downland.

Presentational point – all the habitats contain a lot of “padding”. The introduction, context, status etc could be short and to the point. There should be less “pseudo-science”: more plain English.

Conservation Objectives

We would take some quotes from the government’s “Biodiversity 2020: A strategy for England’s wildlife and ecosystem services” to demonstrate points missing or lacking emphasis in this draft LBAP.

Foreword by Secretary of State – The Rt Hon. Caroline Spelman MP

1. “Ambition to halt overall loss of England’s biodiversity by 2020 … longer term, to move from net biodiversity loss to net gain.”

BHWF recommends: Seek to enshrine latter aim in our LBAP.

1. “In our recent Natural Environment White Paper we responded to Sir John Lawton’s call for a more integrated landscape-scale approach. We need to build a wider network of places across England which enable wildlife to thrive and natural processes to be sustained, alongside other land uses such as farming. This will help nature to better withstand future pressures such as climate change – and set our continuing conservation efforts for particular important species into a wider context.”

BHWF recommends: Strong relationship to green corridors, Biosphere and other concepts, to ensure landscape-scale conservation underpins the LBAP and we get bigger, better and more connected (ecological networks), with the principle of ecosystem services as one underpinning philosophy.

Executive Summary

1) “We need to ensure biodiversity is taken into account by decision-makers within sectors which have the greatest direct influence on our biodiversity, and we need to reduce direct pressures on our biodiversity. The approach will vary from sector to sector, covering a variety of uses of land and sea.”

BHWF notes: The decision-makers and issues having the greatest direct influence in Brighton and Hove are;

• the City Council;
• Agriculture : BHCC farmed estate;
• Forestry : bringing BHCC’s woodlands into sustainable management and expand area;
• Planning and Development – BHCC and SDNPA: with protection and improvement of the natural environment, core objectives of planning system and biodiversity offsetting and improvement;
• Water management: BHCC, SDNPA and Environment Agency to fully protect B&H’s drinking water aquifer, to also conserve the natural environment and improve biodiversity;
• Marine: BHCC endorse chalk shelf proposed Marine Conservation Zone and fisheries achieving Good Environmental Status;
• Air pollution: BHCC actions need to tackle air pollution (acknowledged nationally as especially bad in B&H)
• Invasive non-native species

The context (national and county) can be simplified here: it is sufficient to make the links clear to the England Biodiversity Strategy Delivery Plan and Sussex BAP objectives and targets where appropriate in the proposed Actions. Most important is to cut to the core of the LBAP, i.e. the targets for B&H. The context can simply be a short paragraph, with fulll details in the Appendix.

As to the B&H targets: they are far too weak, e.g. 33% of chalk grassland into a favourable condition – Natural England’s Government target for all SSSIs across the country was 95%!

Words need to be definite and avoid terms such as “wherever practicable” or “seek to” as it is unlikely to happen and there is no commitment to do it.

BHWF recommends: Education / interpretation / promotion / public engagement targets are required here too: promoting basic native wildlife awareness for the people of B&H needs to be a core element of the LBAP.

Earth science and Geomorphology aspects need to be included

Geomorphology (and ‘Geomorphological’) means geology, landscape and the earth science features. These physical aspects underpin the natural ecological and biodiversity features we see on the ground.

Locally important Geomorphological Features and a reference to Geological Conservation should be included.

Local Geological Sites should be identified, including:

TQ20/121 The Goldstone, Hove Park

TQ30/135 Stanmer Village

TQ30/236 Black Rock, Brighton Marina

TQ40/174b Coastal section: Friar’s Bay to Brighton Marina

The Booth Museum of Natural History on Dyke Road can provide further details.

The new National Planning Policy Framework (for England) – NPPF – has been published recently by the Department for Communities and Local Government. Although PPS 9 – Biodiversity and Geological Conservation is replaced by the new Framework, the guidance which went with PPS 9 is retained (i.e. Ref 24 in 113 refers to Government Circular 06/2005: Biodiversity and Geological Conservation – Statutory obligations and their impact within the planning system).

Also retained is Local Sites – Guidance on their Identification and Management (2006).

The NPPF contains references to geological and landscape elements in several parts of Section 11 and in the Glossary. We would draw attention in particular to paragraphs 109, 113, 114, 115 and 117. These would appear to provide much needed guidance on useful additions to the LBAP and its importance to the Biosphere Reserve Project application to UNESCO.

BHWF recommends: The Earth science and Geomorphology aspects covered above need to be included

Habitat and Species Objectives

Detailed recommendations for the habitats and species appropriate to the LBAP are provided as an Appendix below. Similarly the fine details which are essential to progressing the diverse elements critical to conserving local biodiversity could also be usefully provided in the LBAP.

BHWF Conclusions

The draft Local Biodiversity Action Plan as currently drafted is not fit for purpose. This current Consultation process is poor suggesting that a difficult to read document with poor content will be the result.

It needs to be re-written in plain English to suit all readers with important supporting detail put into important, but separate, appendices. It would then be a more useful document which encourages people to use it, whether they are specialists or non-specialists.

We see the current draft Local Biodiversity Action Plan as being inadequate in supporting the wildlife and geodiversity elements of the Biosphere Reserve Project and an urgent redrafting is necessary, so that we will feel able to support the final LBAP, thereby supporting the bid to UNESCO.

However, we consider that biodiversity is critically important and will do all that we can to provide more detail that we would see as being useful to preparing a meaningful LBAP.”

APPENDIX

Detailed recommendations from BHWF in preparing the Local BAP are provided in this Appendix. These are collated from a variety of sources. Whilst they cover the diverse range of source material and natural features across Brighton and Hove, this diversity should be embraced as forming part of the Local BAP.

From ‘Biodiversity 2020: A strategy for England’s wildlife and ecosystem services‘, ‘ENGLAND DELIVERY PLAN’ (using their numbering)

DELIVERY PLAN SECTION │ POSSIBLE B&H LBAP ACTION

FRAMEWORK

0.1 Governance Establish governance for B&H BAP – CSP / ‘Wildlife Group’ / ?

0.2 Indicators Agreed indicators (England D B&H) reported annually

0.3 Local delivery Establish role of B&H (& BAP) within Sussex LNP

0.4 Resources Dedicated funding identified & committed

THEME 1 – INTEGRATED

1.1 Eco Networks Consolidate B&H Downs focal area in BHCC policy (Planning & agriculture)

Nature Improvement Area

1.1.3 Monitoring framework Re point 0.2: take species & habitat indicators & agree monitoring (note: how, with who?)

1.1.4 Reporting Reporting system set up (Re point 0.1)

1.1.5 Common approach Align B&H approach with national approach / recording

1.1.6 Trajectories Set up phased (annual?) goals for hitting 2020 targets

1.1.7 Managing risk Contingency plans for target shortfalls & gaps

1.1.8 Engagement Follow national / local recommendations to deliver outcomes

1.1.10 National Parks Partnership with SDNPA (ref: point 1.1)

1.1.11 Climate change Align with ‘One Planet Living’ (through CSP?)

1.1.12, 1.1.13 On SSSIs With NE, increase species diversity on B&H SSSIs & ensure sites can adapt to change, enhancing biodiversity

1.1.15 Local sites Primary role for BHCC to have robust polices & action + effective monitoring & reporting mechanisms.

1.1.16 Transport As LHA, ensure BAP is fully integrated & work with HA & Network Rail to ‘join-up’action (NIA opportunity?)

1.1.17 Government agencies Make (ideally) single contact point with EA/FC/NE(&EH)

1.2 Marine protection Lobby for Beachy Head W (inc. Brighton) to be declared a MCZ

1.3 Species recovery Identify B&H species with biodiversity value & draw up action plan for recovery

1.3.2 Species protection Protect relevant B&H species through policy & practice

1.3.3 Wildlife crime Liaise with Police wildlife officer/s targeting problem areas

1.3.4 Protect marine species Liaise with IFCA over any relevant B&H issues

1.4.1, 1.4.2 Food – genetic diversity Support growing & development of local produce (eg Sussex apple varieties, Southdown sheep, …)

THEME 2 – PEOPLE

2.1.1 People engagement Commend BHCC on starting to engage public in wildlife

2.1.2 Children ‘Eco-Schools’, good start; need to develop ‘learning outside classroom’ esp.on B&H farms, local wildlife sites etc.

2.1.3 Wildlife gardening Promote effective wildlife gardening philosophy (Parks & private gardens)

2.1.4 Greenspace designations Review B&H situation, incorporating NPPF & consult on developing better greenspace protection & conservation

2.1.5 ‘Muck In4Life’ BHCC + partners (NPA etc) to stimulate volunteering

2.1.6 Green Flag All Parks to be managed under Green Flag principles (& more – no chemicals, wildflowers, de-intense mowing etc.)

2.1.7 Green Infrastructure CSP (or other department?) to set up B&H Green Infrastructure Partnership to champion & progress a challenging action plan

2.1.8 Community toolkit Follow Government lead (through NE), bespoke & roll out Natural Environment Toolkit across B&H

2.1.9 Behaviour change Develop programme to effect behavioural change for people to make more sustainable choices & actions

2.2.1 Accounting for biodiversity Ensure impact assessments take full account of the potential effects on environmental impacts on biodiversity.

2.2.2 Natural capital Assessment Quantify and assess B&H’s natural capital & …

2.2.4 Biodiversity duty …Publish BHCC annual report on meeting their biodiversity duty

2.2.5 Businesses How to involve businesses in promoting biodiversity.

2.2.6 Natural Value Ambassadors Get NV ambassador/s to advise BHCC (esp Planning) on valuing & enhancing ecosystems

2.2.7 Health & well-being Adopt Joint Strategic Needs Assessment of health & well-being & commit to action plan …

2.2.10, 2.2.11 Marine Conservation Zones Provide evidence for Beachy Head W MCZ (re. Point 1.2) & help develop management measures

2.2.12 Voluntary marine input Develop Beachwatch monitoring programme & … ?

2.3.1, 2.3.2 Paying for nature services Develop ecosystem services pilot (NIA – with NPA etc) & engage private sector (eg water companies)

2.3.3 Lottery Funding BHCC / NE / local groups etc – work up nature funding bids

THEME 3 – ENV. PRESSURE

3.1.1 Agriculture BHCC ‘agri. policy’ to include promoting biodiversity as a primary aim

3.1.2 Food Food partnership initiative to incorporate biodiversity objectives

3.1.3 Env’tal Stewardship / Target & maximise agri-environment effectiveness on B&H farms, esp HLS,….

Woodland Grant Scheme … to deliver joined-up objectives at the landscape scale

3.3.1, 3.3.2 Woodland / other Working with FC & NE, restore & sustainably manage B&H woodlands, parkland trees, hedgerows.

trees / woods / etc

3.4.1 NPPF Planning: maximise biodiversity protection & opportunity

3.5.1 Biodiversity offsets Consider B&H as a possible pilot area

3.6.1 Water pollution Diffuse pollution, identify areas action plan (Biosphere)

3.6.2, to 3,4and5 Water bodies Adur & Ouse catchment partnership / action incorporated in Biosphere (+NE/EA), to include targeted farm advice / ELS

3.7.1 Flooding / coastal Develop improved ‘natural processes’ approach

3.8.1 Water abstraction (Re. Point 2.3.1-2): work with water company / EA / others

3.9.1 Marine Plans Contribute to marine planning when SE round time comes

3.9.2 Marine litter BHCC / IFCA / others – joined-up campaign / programme

3.9.3 Marine good env. Status Work with marine authorities to achieve this

3.10. Fisheries Seek sustainable fisheries through Food Partnership & other mechanisms to ensure ‘MSC-type’ accreditation …

3.11.1-2,3.4 Air pollution Set targets for reducing air pollution form different sectors: transport, agriculture etc

3.12.1 Invasive alien species Set programme for eradicating invasive non-native species

THEME 4 – KNOWLEDGE

4.1.1,2,3 R&D Partnership with academic institutions to tackle biodiversity issues, as necessary, in B&H BAP / BHCC strategy / etc, inc marine, followingNational Ecosystem Assessment approach.

4.2.1-4.2.2 Monitoring Partnership with SxBRC + Booth support, to ensure robust recording; support monitoring in key sectors, inc. marine biodiversity.

4.3.1,2-7 Data sharing, Further above (4.2.1-2) for biodiversity & wider landscape, ecosystems etc, by reporting, communication indicators recording & publishing (CSP?), all in publicly accessible formats

Local species with high biodiversity value

DETAILED COMMENTS ON HABITATS AND SPECIES FOLLOW….

National Category: Common dormouse Muscardinus avellanarius

Local Name: Hazel Dormouse Muscardinus avellanarius

Comments:

1. Web-links and other references clearly provided

ADD:

* UKBAP = http://webarchive.nationalarchives.gov.uk/20110303145213/http://ukbap.org.uk/UKPlans.aspx?ID=462

* Natural England Species Information Note SIN005

* Sussex Woodland Habitat Action Plan, February 2010

* ‘Hedgerows for dormice: improving wildlife corridors’. PTES, 2010

* ‘Managing small woodlands for dormice: a guide for owners and managers. PTES

2. S.M.A.R.T objectives are provided in the Local BAP which closely reflect Sussex / National BAPs

National:

A. Maintain dormouse populations in all the counties where they still occur.

B. Enhance dormouse populations in all the counties where they still occur.

Sussex:

Expand the current native woodland resource in Sussex by 3881 ha by 2015.(Note: this is not mentioned in the Draft BAP. A modest 50 ha of additional semi-natural woodland is recommended)

3. Other guidance

People’s Trust foe Endangered Species (PTES) have produced guidance material showing good practice. In particular guidance in “Managing small woodlands for dormice” should be followed

4. Are there any obvious improvements or additions which should be included?

Active site management clearly needs adding!

ACTION TO INCLUDE:

– Sites supporting dormice should be identified and advice provided to land managers on appropriate management.

– Manage woodlands and hedgerows to maintain current populations and prevent further habitat fragmentation.

– Maintenance and restoration of woodland

As a general guide, hedge and woodland work is best carried out during November to February when dormice are likely to be hibernating below ground.

Rides and glades provide increased edge habitat within your wood and ensure light reaches the woodland floor.

Maintain tree branch connections over the rides at pinch points every 50m to enable dormice to travel throughout your woodland.

Some mature fruiting hazel should be retained along ride sides if possible.

– Maintenance of hedgerows of very high environmental value

To produce the most suitable hedges for dormice, management should aim to produce thick bushy hedges that are 3 to 4 metres high. These are likely to only need cutting every third year or less and ideally one third of hedgerows should be left 7 to 10 years between cutting.

Encourage the favourable management of hedgerows and hedgerow trees. Halt the net loss of species rich hedgerows through neglect, removal or inappropriate management

restore hedgerows to benefit wildlife, particularly dormice, that depend on them by reversing the unfavourable condition of existing hedgerows

Seek to increase the numbers of native, species-rich hedgerows in favourable condition in Brighton and Hove.

Encourage planting of native, mixed hedgerows where compatible with landscape guidelines, particularly where they will help provide connectivity on a landscapescale. Species used should be compatible with that Character Area.

Maintenance and restoration of successional areas and scrub

Allow natural regeneration to occur and encourage structural diversity. This method of restocking the woodland can, if necessary, be reinforced by group planting species native to the site, and of local provenance.

In woodland that is deficient in natural tree holes, nest boxes can provide a suitable alternative. These could be erected at a density of 10-30 per hectare, though a higher density (36 per hectare) is recommended for dormouse population monitoring.

Non-native, invasive plants are considered to be one of the greatest threats to biodiversity.

Manage sycamore: Sycamore can be beneficial for dormice in your woodland at low densities as it produces flowers and supports a high number of insects that dormice feed on. However, sycamore produces copious seed which, if left unmanaged, will produce stands of trees that quickly shade out the understorey. They can be managed by coppicing which will maintain the supply of insects without allowing them to seed. Excess saplings should be removed.

Working with local partners, establish a network of dormouse dispersal routes and potential habitat by restoring hedgerow corridors between isolated populations.

Support training in conservation of dormice both for land managers and advisers.

Incorporate National Dormouse Monitoring Scheme to local sites to obtain sufficient long-term data on which to assess the effects of site management and successional development.

Ensure that landowners, agencies and local authorities are aware of the requirements of the dormouse, especially the impact woodland and hedgerow management may have, and the effects of habitat fragmentation.

Ensure continued public awareness of this species as a key indicator of desirable woodland and hedge conditions.

Specifically local aspects which could be included:

Expand the area of semi-natural woodland suitable for dormouse by 50 ha of connected new woodland.

Improve woodland and hedgerow management within Brighton & Hove.

Ensure connectivity is maintained with the adjacent woodland and hedgerows in neighbouring authorities.

National Category: White-letter hairstreak Satyrium w-album

Local Name: White-letter hairstreak Satyrium w-album

1. Web-links and other references clearly provided

– 1989 Section 9.5 Wildlife & Countryside Act 2010

– Butterfly Red List – Endangered

– JNCC Notification, see http://jncc.defra.gov.uk/_speciespages/2586.pdf

– Butterfly Conservation website http://butterfly-conservation.org/Butterfly/32/Butterfly.html?ButterflyId=52 AND www.butterfly-conservation.org/uploads/bc0010%20White-letter%20Hairstreak.pdf

2. S.M.A.R.T objectives are provided in the Local BAP which closely reflect Sussex / National BAPs

National objectives are:

– Ensure the planting of Dutch Elm disease resistent Elm in the English countryside

– Improve delivery of agri-environment andWoodland Grant schemes (appropriate hedgerowplanting, woodland management)

– Ensure current management of remaining sites isappropriate (retaining elm trees, coppicingsuckering elm on a 10 year cycle, sensitive hedgerow management)

– Encourage monitoring (and survey), co-ordinatedata and produce trend for UK and national indicators

Obvious improvements or additions which should be included?

This butterfly prefers flowering trees, therefore strengthen the reference to Dutch Elm Disease control (the principal food plant of the White-Letter Hairstreak is Elm) from simply ‘maintain the cordon sanitaire’ to ‘ensure continuation of DED control programme throughout the city and work with adjacent local authorities to maintain buffer zones within and adjoining the current DED Control Area.

’The ‘Work Programme’ section of the White-Letter Hairstreak entry in the draft B&HLBAP should specifically include the establishment of butterfly gardens, majoring in nectar sources available June- August inclusive.

Consider, where areas of Elm are lost to DED, replanting not only with disease resistant Elm, but also Common Ash, Field Maple and Lime, all thought to be important to this butterfly, the last especially as a nectar source. This would also provide diversification in the local tree stock in case of failure to control DED in the future.

Pick up the recommendation in the National BAP and encourage the planting of more hedgerows on B&HCC farms including Elm to improve connectivity with wider countryside.

Additional Comments:

– Two excellent signs by the ‘Preston Twins’ illustrate the White-Letter Hairstreak and make the connection with Elm. More like this would help in the public education programme and thus with the survey needed to establish the levels of the local population.

– A potential ‘Flagship Species’ for the city through its connection with Elm. As the city holds the National Elm Collection this makes Satyrium w-album a candidate as an indicator of elm tree health.

National Category: Glowworm Lampyris noctiluca ,

Local Name: Glowworm Lampyris noctiluca

Web-links and other references clearly provided

The UK Glow worm Survey website http://www.glowworms.org.uk/conservation.org/

Glow-worm work in progress in some other counties is detailed on the following websites:

• Essex glow-worm survey: http://website.lineone.net/~galaxypix/instructions.htm
• Dorset (glow-worm hunt): www.imagesofdorset.org.uk/Dorset/079/intro.htm
•  

The LBAP draft has included the name of glowworms under “Some associated species”, but there is no further elaboration to provide S.M.A.R.T objectives.

4. Are there any obvious improvements or additions which should be included?

This species is important to Brighton & Hove. Additional details are:

Tyler (2002, p54) lists L. noctiluca’s habitats as “downland, pastures, meadows, roadside, verges, hedgerows, railway embankments, churchyards, golf courses, gardens, moorland, heathland, quarries, canal towpaths, and waste ground”.

He considers that the structure of vegetation, in other words its height, density, shade and shelter, may be more important than its composition. Also, a mixture of open grass and some form of cover such as scrub, brambles or woodland edge is preferred to pure woodland or pure grassland. As glow-worm females and the larvae are flightless, past accessibility is also a significant factor. Suitability as habitat for snails must also be important.

Habitat destruction is similarly talked about as a potential cause of population decline. Alexander (1992) emphasises that the main objective of management for L. noctiluca should be to maintain vegetation structure and snail populations. Wherever possible, the available L. noctiluca habitat should be extended in an effort to link it to other favourable areas. Patches of scrub and dead wood should be retained within open grassland areas to provide cover for larvae and snails (Alexander 1992). In some reserves wooden boards have been laid out on the ground to provide additional shelter for glow-worm larvae.

British populations of L. noctiluca have decreased considerably in numbers over the last fifty years. It is anticipated that this decline is continuing to this day. Secondly, this decline is evident over the entire range of L. noctiluca in Britain. Thirdly this decline is not restricted to one particular habitat type. A fall in numbers has been observed equally in grassland, fenland, woodland and coastal sand dune habitats.

Little empirical data is available as to the actual causes of glow-worm population decline in Britain. A number of theories have been present and one which has been to be investigated is the impact of light pollution. However, much more work needs to be conducted in order to appraise the situation fully.

On pastureland, grazing systems should preferably be extensive and organic. The use of fertilisers and herbicides will degrade the habitat for molluscs and so deprive glow-worms oftheir food.

Scrub management is also an issue as scrub development reduces glow-worm habitat. Scrub clearance will be necessary on unmanaged sites such as disused railway lines

The best form of grass cutting management may be: No grass cutting at all during the glowing season (from the beginning of June until the middle or end of August)

If cuts are vital, they should be kept high in order that the insects are not harmed.

Cut material should be left lying rather than collected

Cutting in wet weather should be avoided to prevent a thick mat of cut material beingproduced, which would be difficult for a glow-worm to navigate (Scagell, 2003).

On pastureland, grazing systems should preferably be extensive and organic. The use of fertilisers and herbicides will degrade the habitat for molluscs and so deprive glow-worms of their food.

Scrub management is also an issue as scrub development reduces glow-worm habitat. Scrub clearance will be necessary on unmanaged sites such as disused railway lines

Female glow-worms and the larvae are flightless and consequently colonisation of new sites is unlikely. This increases the importance of ensuring the protection of existing sites.

The threats to L. noctiluca are similar to those faced by many other species of insects and indeed other invertebrates generally.

Wherever you find small snails, it’s worth looking for glow worms. They prefer open grass or hedges to woodland, but rarely are they to be found on land which has been ‘improved’ for agriculture.

Objectives:

1. To protect existing populations.

2. To increase public awareness of glow-worms, their habitats, the threats they face and the need to protect them.

3. To increase the number of glow-worms in Brighton & Hove.

4. Determine the distribution and status of glow-worms in Brighton and Hove.

5. Ensure glow-worms are identified and conserved, including protection from disturbance and inappropriate management.

6. Monitor the main populations of glow-worms to determine changing population levels .

National Category: Part of ‘Boundary and Linear Features’

Local Name: Roadside Verges

Web-links and other references

Highways Agency BAP (currently under review) – www.highways.gov.uk/aboutus/1153.aspx

West Sussex County Council Road Verges HAP Final Draft 2003 www.biodiversitysussex.org/file_download/61/

Surrey County Council Road Verge HAP www.surreycc.gov.uk/sccwebsite/sccwspages.nsf/LookupWebPagesByTITLE_RTF/Road+Verge+Habitat+Action+Plan?opendocument

Are there any other specifically local aspects which could be included?

Ecology

1. The Road Verges habitat incorporates all road verges and pavements within the city boundary. It incorporates a wide range of habitats and contains a great many species.

2. Despite the variety of habitats included, this habitat is unique in that its management is all through the City Council, which presents a unique opportunity to the community.

3. The habitat totals [to be calculated] ha in area and comprises [to be calculated] ha of woodland [to be calculated] ha scrub [to be calculated] grassland, [to be calculated] mature trees. [note: these figures can be obtained from Report previously produced by Brighton University and Sussex Record Centre for the council]

4. Although road safety must be the prime consideration in the management of the road verges in Brighton and Hove, they nevertheless offer a substantial opportunity to improve biodiversity and enrich people’s daily experience of their local environment by integrating biodiversity conservation into their design and management. This can be achieved by a variety of means, such as adapting existing planting to attract birds and invertebrates, or simply managing areas differently. There are also opportunities for more ambitious programmes to create entirely new habitats.

Included Habitats

1.The wide range of habitats included in this category are Woodland, Hedgerow, Scrub, Grassland, Ditches, Ponds

Threats and Opportunities

1. Due to financial restraints, many road verges are managed in an increasingly uniform way which is quick and easy, but which offers few opportunities for biodiversity.

2. Public perception can prevent habitat creation on road verges. Often people associate wildlife with untidiness and unkempt spaces, although this can be avoided with careful site planning and management.

3. The city’s road verges are easy to affect ecologically because they are managed by a single organisation

4. Road verges are a unique opportunity to bring people into close contact with biodiversity, with all its associated benefits to human health and well being.

5. In the case of road verges, people could contribute directly to BAP targets through the identification of areas of particular ecological interest close to their homes or workplaces.

6. A system of Verges of Conservation Importance could be instituted.

MARITIME – Including Brighton Marina

• 3. Fragile Sponge and Anthozoan Communities; on Subtidal Rocky Habitats Includes Marina

• 5 Intertidal chalk

• 11. Sheltered Muddy Gravels subtidal sediments

• 12. Subtidal chalk

• 13. Subtidal sands and gravels

No Web-links or other references were clearly provided, these could include:

http://jncc.defra.gov.uk/page-5706

http://www.biodiversitysussex.org/habitats/intertidal-chalk

http://www.biodiversitysussex.org/habitats/intertidal-underboulder-communities

http://www.biodiversitysussex.org/habitats/subtidal-chalk

http://www.biodiversitysussex.org/habitats/subtidal-sands-and-gravels

No S.M.A.R.T objectives are provided in the Local BAP, but examples could be followed from:

Kent LBAP has the following:

• Littoral Rock:: http://www.kentbap.org.uk/habitats-and-species/broad-habitat/littoral-rock/

• Inshore Sublittoral Rock:: http://www.kentbap.org.uk/habitats-and-species/broad-habitat/inshore-sublittoral-rock/

• Supralittoral Sediment: http://www.kentbap.org.uk/habitats-and-species/broad-habitat/supralittoral-sediment/

• Sublittoral Rock: http://www.kentbap.org.uk/habitats-and-species/broad-habitat/supralittoral-rock/sediment

• Inshore Sublittoral Sediment: http://www.kentbap.org.uk/habitats-and-species/broad-habitat/inshore-sublittoral-sediment/

• Littoral Sediment: http://www.kentbap.org.uk/habitats-and-species/broad-habitat/littoral-sediment/

Obvious improvements or additions are:

• Intertidal Under Boulder Communities

• Inshore Sublittoral Rock

• Littoral Sediment

Plus possibly:

• Blue Mussel Beds – may occur sufficiently to be included, see: http://www.biodiversitysussex.org/habitats/blue-mussel-beds-on-sediment

National Category: Coastal Vegetated Shingle

Local Name: Coastal Vegetated Shingle

No web-links or other references are provided, these could include:

National – (vegetation of drift lines) http://jncc.defra.gov.uk/pdf/Article17/FCS2007-H1210-audit-Final.pdf

National – (perennial vegetation of stony banks) http://jncc.defra.gov.uk/pdf/Article17/FCS2007-H1220-audit-Final.pdf

Sussex – http://www.biodiversitysussex.org/habitats/vegetated-shingle

Conservation Objectives to include:

T1: Maintain total extent of coastal vegetated shingle habitat throughout the UK, and the structures, sediment and coastal processes that support them.

T2: Achieve favourable or recovering condition by appropriate management of XXXha of coastal vegetated shingle systems currently in unfavourable condition by 2010. This should achieve the retention or enhancement of populations of BAP priority species associated with vegetated shingle.

T3: In key locations initiate restoration of shingle communities on arable land over shingle deposits by 2015.

A. Maintain the total extent of coastal vegetated shingle habitat in Sussex with no net loss, and the structures, sediment and coastal processes that support them.

B. Achieve favourable or recovering condition by appropriate management of 353 ha of coastal vegetated shingle systems currently in unfavourable condition by 2015.

C. Initiate restoration of shingle communities on arable land at Rye and Dungeness over shingle deposits by 2015.

D. Create 5 ha of vegetated shingle in the urban environment by 2015 through new development or small-scale habitat creation schemes.

1. Maintain the total extent of coastal vegetated shingle habitat in Brighton and Hove with no net loss.

2. By 2015, establish programmes to achieve favourable or recovering condition of any existing coastal vegetated shingle which is currently in unfavourable condition.

3. Double the area of vegetated shingle in Brighton and Hove by 2015 through new development or habitat creation schemes.

National Category: Maritime Cliffs and Slopes

Local Name: Maritime Cliffs and Slopes

No web-links or other references clearly provided, these could include:

National – http://jncc.defra.gov.uk/page-5376

Sussex – http://www.biodiversitysussex.org/habitats/maritime-cliff-and-slope

Conservation Objectives could include:

T1: Maintain the existing free-functioning maritime cliff & slope resource (including of cliff-top and slope habitat), estimated to be have a length of about 4500 km. This is essentially a ‘no net loss’ target that should take account of the balance between the extent of coast protection works and free-functioning cliff systems (Note: all the cliffs in Brighton and Hove are already protected).

T2: No overall net loss of cliff and slope functionality as a result of coast protection or engineering works.

T3: Increase the extent of Maritime Cliff and Slope unaffected by coastal engineering/coast protection from 250km to 275km by 2020 (Note: may be difficult to achieve in Brighton and Hove die to the high financial value of assets behind the cliff).

T4: Increase the area of cliff-top semi-natural habitats by at least 500 ha (minimum) by 2015. (Note: very unlikely to be addressed in Brighton and Hove because all available land for expansion is occupied by built development).

T5: Achieve favourable or recovering condition for 1,500 km/30% of maritime cliff and slope including cliff-top vegetation, by 2010 (attained in Brighton and Hove).

A. Maintain the existing free-functioning maritime cliff and slope resource (including cliff top and slope habitat).

B. Achieve favourable or recovering condition for 17 km of maritime cliff and slope including cliff-top vegetation, by 2015.

C. Increase the area of cliff-top semi-natural habitats by 211 ha by 2015.

1. Ensure the Maritime Cliff and Slope habitat in Brighton and Hove is maintained in favourable condition.

2. Ensure coast protection works in the vicinity of Brighton to Newhaven Cliffs SSSI are maintained in accordance with professional ecological advice to avoid unnecessary damage to biodiversity. [BHCC Coast Protection; Natural England; BHCC Cityparks ]

3. Ensure management of the cliff top grassland is maintained to conserve its biodiversity importance [BHCC Cityparks ]

4. Monitor the nature conservation value of the SSSI and ensure all landowner/occupiers are advised of the results and of any action which needs to be taken to conserve the biodiversity of the cliffs [Natural England ]

5. All of Brighton’s Maritime Cliffs and Slopes habitat falls within the Brighton to Newhaven Cliffs SSSI

National Category: Lowland calcareous grassland

Local Name: Lowland calcareous grassland

Lowland calcareous grassland (‘chalk grassland’ would be a more accessible term)

Para 1 “Nitrates are leached out … on steep downland slopes” – no, on all downland, with a combination of free-draining soil and porous chalk; soil erosion is more an issue on the steep slopes.

Para 3 – why highlight waxcap fungi, this is a habitat section, not a species / order chapter. From a public popularity point of view, better to note orchids and/or blue butterflies. If one includes waxcap communities, then other classes should be put in, which is not sensible.

Para 4 – the relative importance of the scrub habitat should be highlighted, along with a basic point about succession; scrub is on the increase and is common, chalk grassland is on the decline and is an internationally rare habitat. It is vital that the conservation of chalk grassland is the clear outcome of this BAP; the problems at the Wild Park LNR over trying to conserve and restore this habitat (versus ‘preserving’ scrub / status quo) were great because people did not understand / were not properly informed and engaged in this ecological matter.

Para 5 – surely this is better in an appendix or a link (if computer-based BAP), not part of the main body of a section on habitat. This is the major part of the BAP and should be tightly focused on the habitat, its importance and conservation action.

Paras 6 – 14 – ditto para 5, this is a HAP chapter. No mention of Waxcaps here – ?

Para 15 – as an example of ‘too much text’, losing the essential point of the BAP in unnecessary text, this information on legal definition would be better as a footnote or appendix. Key elements of the following paras are important as short headline points (ie shrp decline … 3% … B&H coverage).

Para 20 a great LOSS and widespread fragmentation.

Para 21 Not sure “dumping of straw bales” is an appropriate term, though the language is more accessible it devalues the section somewhat and strays from the more significant points. “Insidious fertilization” is a rather emotive phrase, such terms are best avoided.

Para 22 is an important one, making it even more crucial to adjust the text in para 4 (re above). And it’s not just Hawthorn scrub – any “over-mature” scrub can have poor biodiversity, such as over-dense, tall stands of blackthorn.

Para 23 Lack of grazing results in taller grasses and then scrub … – need to simply explain the basics of succession (ie that chalk grassland is a plagioclimax, thought that term is for the technical audience, not the general public.).

Para 24 – use of Scientific names – why; consistency too: para 22 refers to Hawthorn, para 23 refers to species by English and Scientific Latin names, para 24 just Scientific Latin.

Para 25 is very weak “ atmospheric pollution … may be having a damaging effect …”. This also needs explanation.

Para 26 – don’t understand why HLS only has the “potential” to introduce good management, surely it’s a condition of the agreement.

Para 27 is a little dangerous and a lifeline to developers. It is too subtle in the words and doesn’t overtly differentiate between genuine ancient chalk grassland and “surrogate calcareous grassland”. As such, it provides the hope value of destroying chalk grassland as it implies that something pretty comparable can be re-created.

National Category: Plants – ALL

Local Name: Vascular plants

The following plants have local biodiversity value and therefore merit inclusion in the Local BAP. These mirror the vascular plants previously listed, and a few more are added. They occur on the Schedule 41 list, or are nationally Rare/Scarce or have local biodiversity significance as ‘Axiophytes’. In many cases they can be assigned to particular habitats and these are indicated (Associated habitats in Bold). Their conservation objectives will often be similar as they can be used as indicators of local biodiversity quality, these are;

OBJECTIVES:

A. Survey plant population at most appropriate time of year to obtain current datum for local population status.

B. Ensure habitat is managed appropriately.This requires informing local site managers (and their sub-contractors) about the plant species’ existence, biodiversity importance and recommended habitat management.

C. Undertake monitoring at five year intervals to measure changes in population status and precise locations.

D. Produce regular reporting system on the local population status to inform site managers and the local biodiversity groups.

In a few cases more detailed objectives are necessary. For example, shepherd’s needle Scandix pecten-veneris grows on a wall and this will be damaged if the wall is cleaned or sprayed with herbicide by the site owner or the local highways agency.