Full details are available on the Institute's website. Link here.
I won't repeat the whole document here, but two items from the statement are worth highlighting.
2. There should be a Favourable Conservation Status Strategy for the species. A clear national strategy should be in place for each species setting out what must be achieved to fulfil international and national commitments for the species concerned. Any local or district level licensing (DLL) scheme, strategy, or new approach taken under new licensing policies should clearly demonstrate how it contributes to the delivery of Favourable Conservation Status for the species in its natural range.
This really should be a given and it is disappointing that Natural England need to be reminded of the fact. In Kent, one of the arguments that Natural England used to collect data from data providers such as myself was that a delay in providing data may prevent Natural England from publishing a Conservation Strategy for GCN in Kent. Unfortunately once Natural England had obtained data they promptly abandoned their promise to publish the strategy document. After using the data to create their model for the county they also promptly dissolved the data sharing agreement. Unbelievable I know and this has resulted in a complete breakdown in trust. It remains to be seen whether NE will review its position.
3. The mitigation hierarchy should be followed. Strategic licensing schemes should require developers to seek all possible means to avoid impacts on protected species and ameliorate them as far as possible before resorting to compensation via strategic licensing. Strategic licensing should not be seen as a ‘licence to trash’ and, whilst delays associated with translocating each individual could be reduced, proportionate efforts should still be made to rescue and relocate species to safety where possible.
One of my particular concerns over the DLL is that it permits the destruction of high quality breeding ponds. I think we all accept that DLL is a development based tool rather than a tool designed to promote conservation. However, NE has taken this approach too far. Not only is it possible for developers to destroy breeding ponds regardless of their importance to local populations, but developers are financially encouraged to do so. Developers that undertake gcn survey work are penalised by having to pay more for their DLL licence than developers that do no survey work. So not only does DLL facilitate the destruction of important breeding ponds, but it does so in a manner that actively reduces the likelihood that data will be collected to demonstrate the impacts. How can the mitigation hierarchy be followed if survey work to collect baseline data is not undertaken?
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