Implications for wild land on leaving the European Union


It has long been my contention that our statutory system of nature conservation is an inhibition to the existence of nature-led land, to areas of self-willed, wild land. The fetishizing of agro-ecological habitats, and the enforcement of a stasis in the composition of those habitats in our protected areas ensures this, and inevitably gives an all-consuming lead in conservation action everywhere, even in areas outside of statutory protection (1). Nature-led, ecological wilding is thus anathema to this agro-ecological approach. It is therefore no surprise that the ideology, funding and implementation of nature protection are all geared towards management intervention, leading me years ago to define it as a conservation industry, rather than as an endeavour of a public will for the unthreatened, undisturbed existence of wild nature. This, and particularly the burgeoning of agri-environment funding, especially over the last decade, has resulted in nature protection being very easily led along a path of neoliberalisation where a state responsibility is shrugged off to arms-length statutory bodies and a corporatised voluntary sector, the priorities for nature protection being set by that very industry and which has shaped the purpose of the funding (2).

While it should be in the power of our national and devolved Governments to change this, the hope for that change comes up against the impossibility that the conservation industry, and particularly the statutory bodies that are the various Governments’ advisers, will jeopardise the monolithic approach that succours them by seeking change through their advocacy to Governments. It is thus a closed circle if our Governments are unprepared to listen to any other advocacy, and which would be less tainted by an obvious vested interest to maintain the status quo. This is why it is important that the UK has entered into supranational agreements on nature protection, since it is sometimes in the detail of those agreements that our Governments can be held to account on nature protection, and they may also by their different approaches, be an influence for change.

Infringement procedures and the influence of a supranational agreement on nature protection

You may have come across the furore attached to the Polish Government action in increasing the rate of logging in the Białowieża Forest (3) and the announcement by the European Commission in June that it had initiated infringement procedures by sending a letter of formal notice that the logging may not be in compliance with the forest being designated as a Natura 2000 site under the Habitats Directive, the Polish Government being given one month to respond (4,5). At this stage, I can find no details of what was in that letter, but it is likely that it will have been informed by the complaint made in April to the European Commission, supported by a range of Polish environmental voluntary organisations (6). At base, the complaint was that a number of primary forest habitat types for which the Białowieża Forest is designated as a special area of conservation under the EU Habitats Directive, are being put at risk by this logging. However, there is an extensive back story to this situation concerning the fact that a substantial area of the forest has a history as a production forest when a British company first started logging it in the 1920s (7); that there are grievances from local communities on the wastage of resources in this production forest by bark beetle-induced die-back of spruce, those trees which could instead have been available to them if there was sanitary logging of infested trees to control the beetle; and the history of local communities asserting that they were the repository of wisdom on wise use of the forest, as revealed at a conference sponsored by the Polish Ministry of Environment in March (8,9). It would seem that local communities have lost patience with conservation science (and conservationists) who argue for allowing the beetle infestation to run its natural course. Thus instead, the Polish Government is setting up a trial to monitor indices of forest natural habitats every five years and make comparisons between areas with non-intervention and with management for bark beetle, in what must be the hope that it confirms to local communities that they have been right all along about how the forest should be managed and used (10,11). The increased rate of production felling continues irregardless.

I was going to use this as an example of where the Habitats Directive, and any other protected area system like ours based on a compositional approach to habitats, is flawed because the presumption is that designation under such a protected area system does not necessarily preclude extractive use, or extraction in the cause of disease mitigation (12). In the main, the implementation of Natura 2000 sites is secured through the national protected area legislation of each EU member state (12,13). Unlike our legislation, where there is no strict protection through non-intervention and a ban on exploitation in designated areas (14) there is a level of strict protection under Polish legislation for protected areas in that part of the Białowieża Forest that is the National Park (see Art 15 in (15)) and where those primary forest habitats should be unthreatened, but this is only 16.5% of the special area of conservation (16). Apart from a few, small, nature reserves, the rest of the special area of conservation is designated as a Protected Landscape Area under Polish legislation, described in that legislation as a worked landscape capable of satisfying the needs of tourism and recreation, and which may have function for ecological corridors (see Art 23 in (15)).

These Protected Landscape Areas in Poland do not disavow rational management of economic activity such as agriculture, forestry, hunting and fishing, even if it is a Natura 2000 site as well, as long as it doesn’t significantly impact the plant and animal species for which protection has been designated under the latter (see Art 23 onwards in (15)). (It must be remembered that our national parks are the equivalent of Poland’s Protected Landscape Areas (17)). It is thus a judgement call about whether a significantly natural, primary habitat feature can persist within a landscape where there is a presumption for extractive use. The genie is out of the bottle now in terms of reinforcing the principle of local community use of this forest - there were likely to be votes that have been bought with that stance. And while there have been calls to expand the protection of the forest by expanding the boundaries of the National Park, it would be no surprise that communities through their local authorities have probably exercised their veto under the Polish legislation on such proposals (see Art 10.1 in (15)). It is thus political and probably intractable given the situation presently in Poland (18)

Good and bad things about the Habitats Directive for wilder land

As it is now, events have passed on, and my original intention in teasing apart the issues in the Białowieża Forest in relation to the fallibility of some aspects of the Habitats Directive is lost, as will be the ability of the Habitats Directive, and its enforcement, to influence our nature protection upon our withdrawal from the EU. Instead, it will just have to act as an example of how a supranational agreement on nature protection can have an influence. There are some good things about the Habitats Directive in relation to wild land, even in the listing of natural (and semi-natural) habitat types in Annex I of the Directive that require designation of special areas of conservation, even though there is no imprecation in the detail necessarily to strictly protect them (19). When the primary, natural habitats capable of self-perpetuation in the absence of human intervention in Annex I are separated out from the secondary, semi-natural, agro-ecological habitats dependent on a farming pressure (12) you can identify what primary habitats that we don’t now have, or have much of, but should have e.g. flood plain woodland (20,21) wooded sand dunes (22) and bog woodland (23). If these primary habitats were allowed to develop here, they would constitute new areas of wild land that give space to wild nature, and which begin to overturn the millennia of landscape modification that has so degraded our natural vegetation (21,23).

The two most important things for wildland in the Habitats Directive are the requirement to study the desirability of re-introducing the former native mammal species of ours that can be found amongst those listed in Annex IV (see Art 22 in (19)) and which includes one, the beaver, whose reinstatement is already underway, as well as lynx, wolf and brown bear, and then couple that requirement with the strict protection that must be afforded all those species listed in Annex IV (see Art 12 in (19)) and which includes as well, other of our native species that we have put at risk over time, such as otter and wildcat. As an adjunct to that strict protection, Annex II has a list of species for which there is a requirement to designate special areas of conservation, and in which those species should be protected from deterioration of their natural habitats and from disturbance (see Art 6.2 in (19)). This Annex also lists beaver and otter, as well as lynx, wolf and brown bear, but disappointingly not wildcat. While there are some lower and higher plant species listed in Annex II and IV that we have at present to strictly protect (24) you have to consider that it would be the presence of system directing top predators in the lynx, wolf and bear that create their own habitat, and beaver, otter and wildcat that strongly influence their own habitat, that would drive the existence of wild land here, given that all require strict protection, meaning that they would have to be given the undisturbed freedom of areas of their natural habitat. That is why it is important that these mammals be reinstated in an upgrading of trophic occupancy (25).

It’s a notion about how wilder land could come about here, that has kept me interested over the years in the Habitats Directive when there are other aspects of it that have been damaging to the prospect of wild land. The most damaging is the requirement to designate and maintain secondary habitats listed in Annex I, and which includes heathland, the artificiality of its origin and maintenance recognised in it being classified amongst the habitats in the Annex as an agro-ecosystem (26). Heathland is one of my major bugbears because its restoration and maintenance has been responsible for driving out a burgeoning wildness in many locations (27). There is also the issue of habitats listed in Annex I that may be primary elsewhere in continental Europe, but which are secondary here (13). I’m particularly thinking of bogs, which are classified as primary habitats in amongst those listed in Annex I (26). This may be the case for extensive areas of natural bog in Fennoscandinavia and the Baltic States, as it is also in western Russia, and where the hydrology is the driving force (28). But it cannot exclusively be the case in upland Britain, where the origin of many bogs is artificial, as is their maintenance (23). Since many upland bogs in Britain are also designated as special protection areas for their wading birds under the Birds Directive, another EU directive (29) then there is an unholy alliance between game shooting interests and the conservation industry in carrying out the mass slaughter of so-called vermin that threaten the wading birds and grouse, as well as the illegal persecution of raptor species, such as the hen harrier (23,30). This fetishising of sloppy peat bogs by the conservation industry holds back the ecological restoration and wilding of our uplands. I would be mightily relieved if and when the conservation industry can no longer parrot that our heathland and bog has the highest protection because of the Habitats Directive, and that it is a major contribution to the conservation of internationally important habitats.

The designation of areas of heathland under both the Habitats and Birds Directive has also revealed one of the more onerous provisions in these directives, in that their influence reaches outside of the boundary of the designation. In theory, the ability to limit the potential impact inside of a Natura 2000 site from activities outside of it, further secures the protection that it may provide, and this is what is intended by Article 4.4 in the Birds Directive (29) and Articles 6.3 and 7 in the Habitats Directive (19). However, it grinds that heathland in Britain, a depauperate and worryingly oversold habitat, precariously populated with a few birds at the northern extent of their range, has been the cause of re-assessments of local development plans and the proximity of new housing and transport infrastructure, and to requirements to make provision for alternative recreational space to reduce disturbance to the birds (31). It is a preciousness taken too far by the conservation industry (32). As it is, the influence of the Birds Directive is oversold by the birdists when its primary aim of ensuring the protection of ALL wild bird species is routinely breached each year by the exemption from protection provided in General Licences issued for control of pest birds such as crows, jays, jackdaws, rooks, magpies and feral pigeons (eg. (33)).

Protecting marine wild nature

The Annexes of the Habitats Directive also list marine species and habitats for strict protection, but the effectiveness of this listing and the influence that has been brought to bear in safeguarding the wild nature of our seas has been mixed. In terms of influence, an infringement procedure was instigated by the European Commission in December 2005 against the UK for not adequately monitoring how effectively our populations of whales, dolphins and porpoises were being protected (34). In a follow up, the Commission issued a Letter of Formal Notice in June 2013 about the lack of special areas of conservation designated for porpoise (35,36) when it is listed not only in Annex IV for strict protection, but also in Annex II for the requirement to designate protected areas (19). The Commission must not have been satisfied with the UK Government response (37) because it then entered the next stage of infringement proceedings by sending a Reasoned Opinion on the 16 October 2014 that noted that despite a large number of harbour porpoise in its waters, the UK had only proposed one small site in Northern Ireland, and had exposed some of the other potential sites identified to the risk of offshore wind farm development (38). The Commission urged the UK to fulfil its key obligations for this species, and gave the Government two months to respond. Since action in the EU Court of Justice could have been the next stage in infringement proceedings, it is no surprise that consultations took place earlier this year on a total of five proposed special areas of conservation off English and Welsh coasts (39,40) and one proposed area off the Scottish coast (41).

In terms of effectiveness for protecting marine wild nature, the recent consultation by the Welsh Government to open more areas for scallop dredging in the Cardigan Bay special area of conservation (42) just blows holes through the supposedly strict protection of the habitats for which the area is designated, these being sandbanks, reefs and submerged sea caves (43). This is in spite of the Management Scheme for the special area of conservation recognising the damage that scallop dredging does to the seabed (see in (44)). Restrictions on scallop dredging in this special area of conservation have flip-flopped over the years, from a complete ban to a partial area for dredging that was seasonal, and now a wish from the Welsh Government to establish a “viable and sustainable scallop fishery within the Cardigan Bay SAC, incorporating the area which is currently closed to scallop fishing as well as the seasonal open area” (45). The complexity of the proposals suggest that the restrictions within which the dredging will be required to operate will be hopelessly un-monitorable and therefore unenforceable. What is additionally concerning about this, is that the special area of conservation is also designated for the strict protection of bottlenose dolphin that feed on seabed-living organisms, as well as breed and succour their young, in the inshore waters of Cardigan Bay (43) and which the dredging could put at risk (45). Since Cardigan Bay is at the heart of one of the new proposed special areas of conservation for porpoise (40) then they may also be put at risk by this inevitable multiple use approach to Natura 2000 sites.

Bonfire of EU directives and the CAP

Whether those areas proposed for porpoise will go ahead is uncertain. Also uncertain is whether the impetus will be maintained for improvements in protecting marine wild nature because of the requirement in the EU Marine Strategy Framework Directive to take measures to achieve or maintain Good Environmental Status for our seas by 2020. (46-48). In the bonfire of other EU directives that may ensue, we should have achieved compliance by last year in our protected areas to the environmental standards and objectives for surface and ground waters required to have been set in river basin management plans under the EU Water Framework Directive (49,50) and under the EU Floods Directive we should have identified the river basins and associated coastal areas at risk of flooding, drawing up flood risk maps by 2013 and establishing flood risk management plans focused on prevention, protection and preparedness by last year as well (51,52). As the winter flooding of the last few years attests, and the misdirected blame game surrounding it, we are no nearer to accepting the need for a rethink on land use in river catchments and natural systems of water quality and management, being completely detached from the current thinking in continental Europe about forests in natural water-retention measures, and in the restoration of flood plains, and which could lead to areas of wilder land (53,54).

I should also make some judgement about the loss of over £3bn a year in subsidies under the Common Agricultural Policy on withdrawal from the EU. There is no straw to clutch for wild land in the recent change in direct farm subsidy to include a requirement for so-called “greening measures” since the ecological focus areas and the crop diversification and permanent grass rules in the new Basic Payment Scheme are just a tinkering with the enforced coexistence of wild nature with farming (55). If anything, direct farm subsidy is the main factor in keeping farming in place in our uplands, when its lack of financial viability could lead to a clear out in favour of wilder land. The new agri-environment funding scheme for England, but with the surprising return to the original name of Countryside Stewardship, now offers a Mid Tier that addresses broad brush environmental priorities in a local area, and a Higher Tier where the “more complex management requires support from Natural England”, application to both being competitive (56). The Higher Tier is business as usual for Natural England in meeting their objectives by channelling funding into massive intervention on statutorily protected and other sites, and which has done so much to kill the wildness in many locations while engendering a moral corruptness in its delivery (57). As Miles King recently observed to me, agri-environment subsidy and nature-led wilding are not only at odds ecologically, but philosophically and administratively too – “Surely the whole point of wilding is not to be constrained by process or outcome led prescriptions?”. It remains to be seen whether and to what extent our Governments replace the direct and agri-environment subsidies that will be lost from withdrawal from the EU, and if the unexpired portions of existing agreements for agri-environment funding will be honoured.

Wild Europe, wilderness resolution and wilderness Convention

Before leaving the European Union, at least in this article, I would want to acknowledge the achievements of Wild Europe (58) an initiative instigated by Toby Aykroyd who, after getting nowhere in the UK in seeking promotion of wild land and wilderness, switched his focus and efforts in 2005 to Europe. The pace at which Wild Europe, from its foundation in 2007, was able have a resolution on wilderness resoundingly passed in the EU Parliament in 2009, was astonishing, and which set in train a series of meetings, production of reports, an agreement on a working definition for wilderness and wild areas, as well as support for an existing national wilderness strategy in Germany and for emerging initiatives in France and Austria, and in developing a strategy for old growth forest protection in Europe (59). That EU resolution and the opportunities it provided, opened me to the possibilities for existence of wildland and wilderness in Europe that just were not available here, allowing me to make a contribution through reviewing the status and conservation of wild land in Europe for the Scottish Government, and in producing a wilderness register and indicator for Europe for the European Commission (59). That our Governments have been deaf to it (except Scotland to a limited extent) might suggest that there will be no loss of influence on wilderness and wild land here on leaving the European Union. However, wilderness for me has not just been about an existence in EU member states, and which is why, when with others I proposed a Convention on Wilderness in Europe in a resolution at the World Wilderness Congress in Salamanca in 2013, it called upon ALL European countries to join together in a European Wilderness Convention (60). It was our intention that this convention be hosted by the Council of Europe, rather than the European Commission, and it still is. It is through the Council of Europe that there exists another supranational agreement on nature protection that we are signatories to, along with 47 other European countries (as well as the EU itself as an organisation – (61)) and to which our Governments can be held to account on nature protection, and be an influence for change. At that level of participation of European countries, it far exceeds that of the 28 member states of the EU, as it does also the 33 member countries and six cooperating countries of the European Environment Agency (62) an agency set up by the EU to provide independent information on the environment (63). I suspect we will still be a member country of the European Environment Agency, even after leaving the EU.

A Convention on nature protection for all European countries

In writing about the debacle of badger culling In England a couple of years ago, and how it raised ecological issues through ecosystem perturbation resulting from removing a mesopredator from our landscapes, I noted that the Badger Trust had made a complaint under the Convention on the Conservation of European Wildlife and Natural Habitats (64). This is the Bern Convention from 1979, a binding pan-European treaty for the protection of nature under the auspices of the Council of Europe, and a forerunner to the Habitats Directive, the latter being adopted to enable implementation of the Convention by the EU (65,66). I did not explain then the reason why the Badger Trust had made their complaint under the Bern Convention, and not the Habitats Directive. Given that the legislation here protecting badgers was proving ineffective, with Natural England too easily issuing licences for exemption from that protection (64) the Trust turned to the Convention where the badger is given a measure of protection through its listing in Appendix III of the Convention (67) whereas it is not listed for protection anywhere in the Habitats Directive. The Trust also pointed out that the culling of badgers was likely to directly or indirectly effect other species and their habitats that are given strict protection under the Convention through listing in Appendix II (68).

You will see a pattern here of these supra-national agreements using listings in Annex/Appendix to identify priorities for protection, but also levels of protection. It is no coincidence that our principal legislation for species protection, the highly amended Wildlife and Countryside Act from 1981 (69) describes a level of protection given to listings of birds (Schedule 1) animals (Schedule 5) and plants (Schedule 8) because that act was the way in which we transposed and implemented the Bern Convention into our legislation (65, 70). Thus Article 5 of the Bern Convention (71) sets out the special (strict) protection of wild flora species in Appendix I (72) and in Article 6 the special protection of wild fauna species in Appendix II, and which includes wolf, brown bear, otter and wild cat, as well as a range of birds (73). If you were expecting to see lynx and beaver in Appendix II, then these appear instead in Appendix III, along with pine marten, badger, weasel, polecat, and all native deer species (67). Listing in Appendix III should still provide some protection, but it is recognised that amongst some of the species, there may be population control or exploitation, and this needs to be regulated through such as closed seasons, and temporary or local bans on exploitation (see Art 7 (71)). Indiscriminate means of capture and killing species listed in Appendix III are ruled out by Article 8, and which points to a fourth Appendix that lays out a range of prohibited means and methods of killing, capture and other forms of exploitation (74).

The Convention does not list specific habitats for protection, but Article 4 is a catch all in that it requires protection of the habitats of all native flora and fauna, but particularly of those strictly protected species in Appendices I and II. While there is no requirement to designate protected areas for species or habitats under the Convention, there has since been a non-binding recommendation and resolution from the Standing Committee (as set up by the Convention – Art 13 (71)) that requests parties to the Convention to designate areas of special conservation interest as part of an Emerald Network, and which mirrors the Natura 2000 network (see Recommendation 16 and Resolution 3 in the Appendices to (75)). There a number of conditions that could be met in designating one of these areas, but the most important ones are where it will contribute substantially to the survival of threatened species, endemic species, or any species listed in Appendices I and II, or where it contains an important and/or representative sample of endangered habitat types. Other resolutions have identified endangered natural habitats and species requiring specific habitat conservation measures (Resolutions 4 and 6 in the Appendices in (75)). As of now, Switzerland is the only party to the Convention that has an official list of protected areas in the Emerald Network (76) but there are 14 other countries (including Russia, Norway, and many eastern European countries) that have nominated lists of candidate Emerald sites (77). It would seem likely that our Natura 2000 sites could be rebadged into the Emerald Network, but I would much prefer that we make better use of our Marine and Coastal Access Act 2009 to designate existing marine protected areas in the Natura 2000 network and the new ones proposed for porpoise (see above) as Marine Conservation Zones under the Act, and which have conservation objectives in the designation that recognised a range of restrictions within a spatial model (78).

As with all these supranational agreements, and national legislation on nature protection like ours, there are get-outs that provide exemptions from some of the provisions. Thus Article 22 of the Convention can be used early on by the contracting parties to make reservations from the species lists in Appendices I-III, and in the methods of killing and capture in Appendix IV (71). There is a long list of reservations sought by individual countries, many of them being reservations on the protection of large carnivores, but since we don’t have any, our reservations were mostly about exceptions from the prohibition on killing and capture listed in Appendix IV (79). Under Article 9 in the Convention, ongoing exceptions can be made to habitat conservation in Article 4, the species protections in Articles 5, 6 and 7, as well as the prohibition of the use of means of capture and killing under Article 8 (71). These exceptions have to be justified under a limited range of conditions, such as to prevent serious damage to agriculture, in the interests of public health and safety, or for the purposes of research and education, provided that a report is made every two years to the Standing Committee that specifies amongst other things the populations which are or have been subject to the exceptions, the means authorised for killing or capture, the authority empowered to declare that these conditions have been fulfilled, and the controls involved. There is only one biennial report currently available that I can find for the UK, and which covers 2009 to 2010 (80). This contains an extensive list of the number of licences issued for actions, mostly in respect of research, involving strictly protected species in Appendices I and II, and also an exceedingly long list for species in Appendix III but where there were other than non-research justifications.

I’ve already alluded above to the monitoring process of the Bern Convention by way of the complaints made by the Badger Trust, which used the case-file system that dates back to 1984 (81). The system allows complaints to be submitted by anyone and, if deemed relevant, are dealt with by the Standing Committee, which can seek information from contracting parties as well as arrange on-the spot visits. There is no ultimate judicial sanction associated, as there is with the infringement process under the Habitats Directive (see above) and thus compliance relies on a commitment to the Convention, along with loss of peer standing amongst contracting parties to the Convention. You should know that there is another way that esteem can be dented under the Convention. I’ve written before of the European Diploma of Protected Areas in relation to Šumava National Park (82) a scheme where a Diploma is awarded by the Council of Europe, administered by a Group of specialists under the Standing Committee of the Convention, to protected areas of European interest that show effective management of their biological, geological or landscape diversity (83). I note this here now because the Diploma awarded to the Białowieża National Park is up for renewal. However, at a meeting in early March of the Group of Specialists on the European Diploma for Protected Areas, a decision was taken, based on the evidence in an extensive site visit report from last September (84) and because of rumblings in the press and complaints from NGOs, and after asking for clarification from the Polish Government (which just replied that observers should just come to the conference sponsored by the Polish Ministry of Environment in March, and thus after the meeting of the Group - see above) that it would not propose the renewal of the Diploma because a “new Government forest management plan may affect negatively the area surrounding the National Park” (85). This snub to the Polish Government from the Council of Europe about the logging in the Białowieża Forest preceded instigation of the infringement procedure against Poland by the EU.

Driving the existence of wild land here

So how does the Bern Convention stack up for influencing the potential of wild land here? There is an encouragement under Article 11 to reinstate former native species, and so this maintains an external influence on us under a supranational agreement to consider reinstatement of wolf, lynx and bear (71). While otter and wild cat that are already here must have strict protection under the Convention, so too would wolf and brown bear when reinstated. What I also like is that Article 12 says that contacting parties can adopt stricter measures for protection than provided under the Convention (71). We could thus choose to give beaver stricter protection than is provided for by Appendix III, as we could also lynx when reinstated, but both along with pine marten, badger, weasel and polecat should anyway receive a measure of protection under that Appendix. Thus the Convention does give us an impetus for an upgrading of trophic occupancy, coupled with strict protection of key mammalian species. However, there is only a request to contracting parties to designate areas of special conservation interest, but the species for which the request was originally formulated has been broadened from just those listed for strict protection (wolf, bear, wildcat, otter) to also include the lynx and beaver as well (see the revised list of species requiring specific habitat conservation measures in Resolution 6 in the Appendices in (75)). Thus all the elements that could drive the existence of wild land here, and where wild species are given the undisturbed freedom of areas of their natural habitat, are also possible under the Bern Convention.

I did not ever expect to be carrying out this analysis, and whatever are the arguments about withdrawal from the EU and the eventual outcome, there has to be some continuing hope for an external influence for wilder land here, and which I have attempted to show. It is perhaps a painful irony in the rejection of EU membership that there are many parts of the Bern Convention that encourage co-operation amongst contracting parties, especially in relation to migratory species, in essentially what is a supranational agreement to ensure protection of native species in Europe in their natural surroundings. In thinking of other influences from Europe, it is time now for Wild Europe to broaden away from the EU as being its main focus of achievement, and seek a relationship with the Council of Europe, and particularly with the Standing Committee of the Bern Convention. In that way, those interested in wildland in the UK, and what lessons can be learned from the whole of Europe, could still have a legitimate role in Wild Europe, as the UK is a party to the Bern Convention – as is the EU.

Mark Fisher 5 July 2016

(1) The most unnatural conservation policy possible, Self-willed land July 2010

(2) The neoliberalisation of nature conservation, Self-willd land February 2013

(3) Last stand for Europe's remaining ancient forest as loggers prepare to move in, Arthur Neslen, Guardian 18 May 2016

(4) INFRINGEMENT PROCEDURES - Environment - Poland/forests: - Q&A. LIVE EC Midday press briefing of 16/06/2016. European Commission

(5) NATURE - Increased logging in Białowieża Forest, Infringement number 20162072, European Commission

(6) Complaint to the European Commission concerning alleged breach of Union law Failure to comply with Articles 6(2) and 6(3) of the Habitats Directive and Article 4(4) of the Birds Directive (by virtue of Article 7 of the Habitats Directive) in relation to the revised Forest Management Plan for Bialowieza Forest District April 2016. Fundacja ClientEarth Poland

(7) The Białowieża Primeval Forest. Conflicts over its conservation and management. The State Forest Information Centre Poland, 2015

(8) „PUSZCZA BIAŁOWIESKA - MITY, FAKTY I PRZYSZŁOŚĆ" - PREZENTACJE I PRELEKCJE, Ministerstwo Środowiska 14 March 2016 ("Bialowieza Forest -Myths, Facts and the Future"- presentations and lectures. Ministry of the Environment)

(9) Wnioski Konferencji (Conclusions of the conference)

(10) ACTION PROGRAMME FOR THE BIAŁOWIEŻA FOREST SIGNED, Ministry of the Environment 25 March 2016

(11) Program for the Bialowieza Forest as the cultural and natural UNESCO-heritage and the area of Natura 2000 network worked out by the Minister of the Environment, Prof. Dr. hab. Jan Szyszko and General Director of the State Forests, Dr. Konrad Tomaszewski.

(12) Protected areas in Europe – Natura 2000 versus national protected areas, Self-willed land January 2013

(13) Fisher, M., Carver, S., Kun, Z., Mcmorran, R., Arrell, K. & Mitchell, G. (2010) Review of Status and Conservation of Wild Land in Europe. Project commissioned by the Scottish Government

(14) Written evidence submitted by the Wildland Research Institute, University of Leeds, to An environmental scorecard, HC 215 Environmental Audit Committee House of Commons. 2 July 2014

(15) USTAWA z dnia 16 kwietnia 2004 r. o ochronie przyrody (Nature Conservation ACT of 16 April 2004);jsessionid=32EE2FEC3611DE5C9D286AE26B116D1C?id=WDU20091511220&type=3

(16) Puszcza Białowieska PLC200004. NATURA 2000 - STANDARD DATA FORM

(17) The IUCN categories, National Parks UK

(18) Poland politics: former presidents attack ruling party, BBC News Europe 25 April 2016

(19) COUNCIL DIRECTIVE 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora (OJ L 206, 22.7.1992, p.7)

(20) Flooding and cherry picking, Self-willed land February 2014

(21) The natural vegetation of England, Self-willed land August 2014

(22) Untamed nature, Self-willed land 20 March 2014

(23) The free for all of trophic rewilding, Self-willed land January 2016

(24) Individual Species Reports - 3rd UK Habitats Directive Reporting 2013, Joint Nature Conservation Committee

(25) Trophic occupancy and the rehabilitation of the meaning of rewilding, Self-willed land April 2016

(26) Annex 2 Allocation of Annex I habitat types for each ecosystem. EU 2010 Biodiversity Baseline – Annexes EEA Report No 12/2010

(27) Heathland MADNESS - the juggernaut of nature conservation, Self-willed land 2008-2014

(28) "peatlands are more important than tropical rainforest", ssenredliW - what does it mean? Self-willed land March 2012

(29) DIRECTIVE 2009/147/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 November 2009 on the conservation of wild birds

(30) "Legal control of crows, foxes and stoats", ssenredliW - what does it mean? Self-willed land October 2008

(31) Heathland and the perception and preference for landscape, Self-willed land March 2010

(32) Rare and precious – words devalued by the conservation industry, Self-willed land May 2011

(33) GENERAL LICENCE To kill or take certain species of wild birds to conserve flora and fauna. Natural England WML – GL06

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