Lee Brady's Recording Blog

CIEEM Updates Its Position Statement on DLL

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? 

 

GCN and Arable - Some Thoughts

 

[this information was originally in the previous post, but I put it here to unclutter the status assessment]

 

Mike Phillips dropped me an email to query the arable. So I thought it worthwhile to post my thoughts. 

A problem we have is that there is little available quantitative data on terrestrial habitat use. Since most gcn records are collected from ponds, the model is therefore scoring terrestrial landscape features based on their suitability as locations for gcn ponds. 

A grassland location scores much better than a woodland location (the latter barely positive). Arable is in the middle. Builtup locations and locations with conifer typically score negatively (ie. newts are infrequently recorded in these areas). 

One possible modification to the status assessment would be to provide a range of values. For terrestrial habitat, the lower range would exclude arable, the maximum would include it. However, I am reminded of mitigation projects that capture many gcn in arable fields.

Since the model used for the Kent Status Assessment is summing the % habitat cover in only those squares where gcn presence is predicted, it already controls for arable areas with high % cover where gcn are likely to be absent.

Looking at the model outputs, 1 km squares with very extensive % cover of arable cannot overcome the low score generated if the square has few ponds. So 1 km squares with very high (>90%) arable cover and 3 or less ponds typically generate a Low score in terms of their suitability for gcn.

In comparison, 1 km squares with few ponds and high % cover of improved grassland will usually generate a Medium score in terms of their suitability for gcn. 

Of course the overall score depends on the mix of landscape features that are present, with pond density being the main positive influence (by a long way).

Expressed another way. A 1 km square located in the range of gcn with very high arable % cover will need more ponds created than a square with a lower % cover of grassland to achieve the same suitability score. 

For interest, the highest scoring 1 km square with low pond density (3 ponds in this case) has the following mix of terrestrial habitat classifications:

Improved Grassland = 54.7%
Arable = 39%
Broadleaf = 0
Conifer = 0
Semi-Natural = 2.6%
Upland = 3.7%
Builtup = 0

For low pond density squares with an overall score of High, the square with the highest arable % cover has the following composition:

Improved Grassland = 22%
Arable = 63.4%
Broadleaf = 0
Conifer = 0
Semi-Natural = 6.6%
Upland = 7.8%
Builtup = 0

(there are 3 ponds in this square and gcn are confirmed present)

 

Last comment. Providing there are a reasonable number of ponds present, the presence of arable will not prevent pond occupancy by gcn - providing the square is actually within their range.   

 

Woking Consultation Document - (3) Favourable Conservation Status

In the Q&A section of the Woking consultation document, one of the questions is (pg. 11):

 

"Does the proposed scheme risk contravening the legislation which protects GCN?"

 

The answer is as follows:

 

"As with any other protected species application, before an organisational licence is issued, the proposals will be assessed against the three legal tests required under in the Conservation of Habitats and Species Regulations 2010 (as amended) (the “Habs Regs”), namely:

• 􏰀  Purpose (in this case: imperative reasons of overriding public interest including those of a social or economic nature and beneficial consequences of primary importance for the environment);

• 􏰀  That there is no satisfactory alternative;

• 􏰀  That the action authorised will not be detrimental to the maintenance of the species concerned at a favourable conservation status in their natural range. 

Under the Habs Regs, Natural England is the competent licensing authority and will ensure that the three licensing tests are assessed objectively."

 

Emphasis mine. 

The consultation document defines FCS (pg. 14):

 

"a situation where a habitat type or species is doing sufficiently well in terms of quality and quantity and has good prospects of continuing to do so in future."

 

The current system of gcn licensing requires consultant ecologists to prepare a method statement that incorporates actions designed to ensure that the FCS test is met. NE review licence applications. If they are not satisfied that FCS will be met, the licence is rejected. The Woking pilot will require NE to grant Woking BC an organisational licence to implement the scheme. 

You can therefore imagine my surprise when I read on pg. 30 of the Woking consultation document:

 

"This strategy does not seek to define a Favourable Conservation Status or Favourable Reference Values for GCN in the Borough..."

 

If the proposed strategy does not seek to define FCS for gcn in Woking, then how will the third test be met? Or have I missed something? 

 

Further Thoughts on Woking - (2) Distribution Modelling & Sample Sizes

Here's where we start to get to the nitty gritty of the Woking Pilot project. How many ponds were actually sampled to inform the distribution modelling? Was it enough to support the conclusions made in the consultation document?

The document published by Woking BC is intended to be read and understood by local residents and is therefore not scientific in its nature. And I certainly don't have a problem with that. Creating documents that are accessible to as many interested parties as possible should be encouraged. An attempt has been made to include Annexes that provide more detail and these include useful summary points. The problem with summaries though is that they can be misleading. The conclusions drawn may not be justified by available evidence. Without access to all data it may simply not be possible to undertake a detailed review. I won't let that stop me trying though. 

Data on gcn distribution in Woking appears to have been collated from information held by Surrey Amphibian and Reptile Group, Surrey Wildlife Trust and directly sourced from an eDNA and HSI study funded by the pilot project. Let's dig a little and pull out some numbers. 

 

Total number of ponds in Woking - not specified

Number of ponds assessed for HSI = 100 (pg. 20)

Number of ponds assessed for eDNA = (50 stated on pg. 20; 48 stated on pg. 33)

Number of ponds assessed for both HSI & eDNA = 36 (pg. 33)

Number of ponds with positive eDNA results = 5 (pg. 33)

Number of additional ponds with verified gcn records = 8 (pg. 33)

 

These are very (very!) small sample sizes. We don't even know what proportion of the available ponds they represent. I'm also confused as to why HSI assessments were not taken for all of the ponds sampled for eDNA (only 36 out of 50/48)?

There's also no confirmation that the HSI and eDNA data was collected following all appropriate guidelines. NE have quite rigorous requirements for eDNA sample collection. Were these guidelines actually followed? 

The author(s) have attempted to correlate the results of the 36 ponds assessed for both HSI and eDNA with landscape level habitat variables derived from Land Cover Map 2000 (pg. 33):

 

"The results showed a positive correlation with the extent of urban areas within 250m (or a negative correlation with distance from urban areas) and a negative correlation with the extent of arable land. This suggests that urban areas may provide a greater diversity of habitats required by GCNs than arable areas. They also showed a weak negative correlation with the extent of woodland and conversely with distance to heathland."

 

That's quite a bold statement for a study based on just 36 ponds, only 5 of which were found to be occupied by gcn (assuming these 5 were all in the group for which HSI data was collected). 

My own work investigating the relationship between gcn and landscape habitat variables does not support these conclusions. In Kent, gcn are negatively associated with urban areas and appear somewhat neutral with respect to woodland. The Kent dataset is based on a sample of several hundreds of occupied ponds across the whole county. Since the Woking project did not assess ponds across the whole of Surrey, the relationship between gcn presence and landscape habitat variables is highly biased since it is significantly influenced by the extent of each habitat category present in the borough. Looking at the Woking BC map, it appears that much of the borough is dominated by an urban landscape. 

 

 

Results have been used to identify three metapopulations (Fig. 1, above) and these are described as follows:

 

Littleneck - 'a small number of ponds' .. 'largely in good condition'

Hook Heath  - 'only one or two ponds'

Westfield - 'a larger number of ponds' ... 'in poorer condition'

 

These descriptions really are a bit woolly! Are these occupied ponds or all ponds? What does 'a small number of ponds' mean? Three ponds? Four ponds? At Hook Heath there were 'one or two ponds'. Which was it? Surely the authors know?! What does 'larger number of ponds' mean? Five or twenty five? Come on this wouldn't be acceptable for an undergraduate project, let alone a project attempting to define the conservation of gcn in a whole borough for the next 25 years!  

 

 

In Woking, the metapopulaton with the highest number of occupied ponds can be inferred by reviewing the zones identified in Fig. 2 (pg. 23 of the report, shown above). Westfield, located to the south, appears to have the most occupied ponds and also happens to be the most rural. You'll also notice that few (if any) of the populations occur wholly within urban areas. 

Although the apparent quality of individual gcn occupied ponds may well be better in locations situated closer to urban areas (especially when subject to positive management work), such ponds can be at greater risk from direct disturbance, introduction of fish and increased fragmentation of surrounding terrestrial habitat. 

The interaction between gcn pond occupancy, pond quality and urbanisation has not been fully investigated within the report and such work is important if we are to more fully understand the Future Prospects of gcn in Woking. For example, if we assume a similar number of ponds in each of the three metapopulations, why was occupancy so low in two of the areas? Could it have been that the overall number of suitable ponds is lower in more urban areas? The HSI assessment does not appear to consider the quality of unoccupied ponds in each of the three metapopulations.

In fact I'll go a step further and propose a different interpretation of the data than that presented in the consultation document. Look again at Fig. 2 on pg. 23. The apparent relationship between gcn occupied ponds and urban areas has nothing to do with the alleged greater range of habitats that these areas may provide. Newts aren't colonising ponds on the edge of urban areas from the surrounding countryside. Urban areas in Woking are expanding and encroaching on existing newt habitat. Previously occupied ponds located within urban areas have been lost. Once urban areas expand to envelop the few gcn ponds that remain they will also be lost. If anything, the study presented here is an indictment of development and could be used to argue that in order to achieve a Favourable Conservation Status for gcn, there should be no more development projects in Woking! I'm fairly sure that's not what the council intended when they published the report for all to read. But I digress... 

 

The results for Maxent modelling reveal the importance of larger sample sizes.

 

"Validating the results against the eDNA results, i.e. the 5 positive records used for training with the 43 negative results suggests that the model is providing a good fit to the training data and absence data GCN results."

 

Remember, the pilot project was using just 5 positive records to inform a distribution model for the whole borough. Is it really a surprise that using the same training data that was used to develop the model produced a good fit? What happens when independent data is tested? 

 

"The SARG records contain eight validated records with 1m grid references within the Woking boundary. Testing these against the Maxent model trained with the eDNA positive records produces a poor fit."

 

Which contradicts an earlier statement made in one of the summaries (pg. 20):

 

"There is a strong coincidence between the predictions from the modelling and the field records"

 

The authors do appear to have subsequently incorporated the SARG records into a Maxent model: 

 

"Training and testing the model using the available positive field records and the negative eDNA records shows an improved fit to the training data combined with the absence data."

 

It's quite revealing that the author(s) do not claim there to be a good fit using the SARG records, only an improved fit. An improvement on poor may well still be poor. Either way, it's something of a stretch to suggest a strong coincidence. 

 

In conclusion, I believe that the sample sizes used in this pilot project are simply too small. A far more rigorous survey programme is required. The fact that there are (pg. 20):

 

"sparse, sporadic records elsewhere in the Borough."

 

Suggests to me that even in a limited areas such as Woking, sampling effort hasn't been sufficiently high to reliably identify all possible metapopulations. In a blog article such as this, I'm loathe to start referencing too much published research. However, there is one conclusion from a 2008 study on the performance of distribution models that I will quote:

 

"No algorithm predicted consistently well with small sample size (n < 30) and this should encourage highly conservative use of predictions based on small sample size and restrict their use to exploratory modelling."

 

M. S. Wisz, R. J. Hijmans, J. Li, A. T. Peterson, C. H. Graham, A. Guisan and NCEAS Predicting Species Distributions Working Group (2008) Effects of sample size on the performance of species distribution models. Diversity and Distributions, (Diversity Distrib.) (2008) 14, 763–773

 

Some Thoughts on the 'Woking Project' - (1) Costs

Reviewing a large project such as this, particular one that attempts to encompass so many different issues is no small challenge. But I've now read the consultation documents and made some conclusions. 

The short version is this. Developing a strategic approach to dealing with planning matters and protected species such as great crested newts will be a huge boon to large developers. If done to a scientifically high standard in a manner that addresses Favourable Conservation Status it could also benefit newts.

However, I think the current pilot project may not be quite so attractive to developers working on smaller schemes that would have a low impact on gcn populations. I'm also not fully convinced by the scientific evidence presented in the report and it is clear that no attempt has been made to address the thorny issue of what great crested newt Favourable Conservation Status means in Woking. 

Since writing about this project will require a lot of words, I think I'll break my thoughts down into digestible chunks and publish these over the course of the next few days (time permitting). And yes, I've deliberately left this to the last minute because I prefer that if folks want to comment on the proposals themselves, they do so without being influenced by me. 

I'll start by looking at the projected costs to developers. 

Developers who sign up to the scheme no longer need to be concerned by undertaking newt survey work in good time. They won't need to worry about planning conditions that state newt survey and/or mitigation work is required. Nor will they need to be concerned by leaving everything to the last minute. Nope, those concerns will be gone. Pay up and build. Unless of course there are other protected species present on the site. In which case (at least until Woking BC draw up provision for including bats, dormouse, reptiles etc), this is all moot since development will still be delayed.

If capture work for slow-worms is undertaken on a site supporting newts, then it is quite possible that newts will be encountered. According to the proposals, under these circumstances somebody still has to move any newts that are encountered. Who? Where will the newts be moved to? What disease control measures will be undertaken? Has Woking heard of Chytrid? What additional costs will this all incur?

There is also an odd payment matrix (detailed on pg. 9 of the consultation document). Apparently it will cost £900 (per development) to participate in the scheme. That sounds relatively inexpensive. But there is also a multiplier that depends on which area of Woking the development occurs in. Areas considered most important for newts have a x3 multiplier associated with them (the 'orange zone'). There is also a multiplier that comes into affect based on the number of ponds located within 500m. Large development projects (e.g.  20+ residential units) in the 'orange zone' that destroy 3 ponds on a site with very high quality terrestrial habitat would therefore be asked to pay £900 x (3 x 3) = £8,100 (+undefined council legal fees). This would be considered very inexpensive for a large development project and would be more than paid for by virtue of the savings made through removal of delays. Yet this price does not really take into consideration the true impact of the development. Rather bizarrely, the report author(s) claims (pg. 28) that

'the value of terrestrial habitat is not correlated with area'

This statement alone makes me highly concerned about the credibility of the author(s) and is certainly at odds with current licensing. Worst still, a small developer building three houses at a distance of 450m from the same three ponds on land displaying low quality terrestrial habitat would have to pay the exact same fee! Such a developer may not have to pay anything for newt mitigation under the existing licensing system. 

The pricing matrix has clearly been designed to favour large developers but in my opinion it is broken and needs a radical rethink. 

Stay tuned for more thoughts... 

 

Woking Borough Council, Newts & Development

"The aim is to take a more strategic approach to the conservation of newts, ensuring that resources are focused on newt populations and habitat that will bring the greatest benefits to the species. At the same time it will make the licensing process much more straightforward for developers on sites where newts are present."

 

The full press release is available here. 

The 2016 Herpetofauna Workers Meeting is nearly upon us and I rather suspect that 'The Woking Project' will be the cause of much heated debate. 

In the meantime, there is an open consultation and the borough council have invited comments from the public. If you'd like to learn more about the project and offer your opinions direct to the policy makers you can do so here. But hurry, you only have until 10th February 2016. 

As you can no doubt guess I have my own views on this project and I'll be sharing my thoughts over the coming days...

 

Great Crested Newts Found at Horish Woods

“With the habitat split by the M20 and rail link, combined with motorway run off which drains into the only pond on site, means that it’s been a surprise to find so many living here.

“In fact, this area has been the most prolific site we have ever had for newts which is a huge shock.”

via www.kentonline.co.uk

Actually this is not such a surprise. Isolated sites often display higher than expected populations of newts. Juveniles have nowhere else to disperse to so local densities can be higher than would normally be anticipated. Detectability issues in finding adult newts at breeding ponds also needs to be carefully considered (example). Low counts of adult newts in a murky pond, do not necessarily mean that the population size is small. 

 

  

'Our Humble Newts Can Defeat the Developers' - Say what?!

Until now, conservationists have used plastic bottles to catch the slippery pond dwellers for four nights in a row. But the trust has devised a laboratory test that can detect if newts are present through DNA traces in pond water.

This could cause more headaches for developers who already face a raft of tests from the impact on historic buildings, overseen by English Heritage, to flood risks set by The Environment Agency.

via www.oxfordmail.co.uk

 

A really poor headline and complete misrepresentation of the facts.

Environmental DNA testing has not been developed to defeat developers but to help reduce costs to developers when survey work is required. 

 

Protected Newts Hold up Firm’s Solar Farm Scheme

Lightsource wants to put almost 16,000 solar panels on fields at Barn Farm, south of the B1352 Harwich Road.

But now the company have withdrawn their plans after Great Crested Newts were found within 2km of the site.

via www.harwichandmanningtreestandard.co.uk

 

Within 2 km of the site? Are they serious?

But I thought ecological consultants were arguing that solar farms benefit wildlife (and newts especially)? Heaven forbid a large population of newts should be found close to the the boundary of a proposed solar farm in Kent. Oh wait...

 

Campaigners Offered Newt Hope

According to Mr Hutchinson, a “lack of sufficient survey effort” by the developer in respect of great crested newts meant he refused to support the plans until a proper survey of newt numbers was carried out to his satisfaction.

via www.elystandard.co.uk

The whole things sounds a bit ridiculous to me. However, it's yet another case study demonstrating why it is important for developers to commission good quality survey work at the right time of year.