 |
Nature improvement and restoration areas - are they a step towards rewilding? |
|
|
I came across a fascinating report from the Wildlife Conservation Society in America that mapped the distribution of six vulnerable species on 1.3 million acres of contiguous public land in Montana, identifying their current and future habitats and the connections between them (1). These essentially roadless and undesignated public lands of the US Forest Service and Bureau of Land Management connect northwards, up the Rocky Mountains alongside existing designated wilderness, to Glacier National Park on the border with Canada. The Park was established in 1910, and is a core wildland area along with the designated wilderness areas in a mostly intact ecosystem formed by these lands that are all in public ownership. While protection in the region has focussed on core wildlands and wildlife, it is now recognised that the resiliency of wild nature is best served by keeping future options open through an emphasis on ecological variability across space and time, and thus the ability to migrate to new areas when conditions change. What this means in practice is an enlargement of the coverage and effectiveness of protected areas coupled with enhancing connectivity within and around large ecosystems, and through reducing the external pressures on species and ecosystems.
The six
vulnerable species were chosen for the study as indicators of critical
habitat, and were grizzly bear, wolverine, mountain goat, bighorn sheep,
the bull trout and the westslope cutthroat trout. Weaver, the report’s
author, spent four months hiking and riding horseback through these remote
roadless areas, seeing for himself the areas of
critical habitat. He then used the distribution maps to rank the
relative
conservation
importance of various areas in the public lands, and make recommendations
for wildland protection: This is an exceptional, large-scale opportunity to complete the legacy of conservation of this Montanan section of the Rocky Mountains for present and future generations. That it is capable of being proposed is because of the public ownership of the land that removes the burden of exploitation, and because of its predominantly undeveloped roadless condition that gives a home to roam for the wild hunters – wolf, grizzly bear, cougar, lynx, wolverine and others – as well as to large populations of bighorn sheep, mountain goats and elk, and to cold clear waters full of trout, all species that have been cleared from or moved out of more settled areas. I
am inspired by the potential revealed by this proposal. I believe that
robust parallels can be drawn from such contemporary
research in N. America and elsewhere, to make the case for a broader view
of the functional ecology of Britain, overcoming the culturally-induced
inertia, and drawing on evidence where it may be found. It is though a
common refrain that N. America has no lessons for the ecology of Britain.
Even tentative explorations of wildness and wildland potential can be
countered as being in thrall to “North American models and examples”
and
that “wildness is entirely subjective” (2). Unfortunately, it is even
embedded in the “arms length” but statutory conservation agency, Natural
England, so unconnected with the aspirations of ordinary people, its Board
members filled with antiquated prejudices such that it asserts a doctrine
of (see section 6.2 (3)):
This is a dead hand at work here, denying the biophysical
and ecological reality of wildness, and which fatally restricts us to
culturally modified landscapes and an inherited incompleteness of predator
species that so reduces our wilder horizons. It is why I had no surprise
that we ended up recently with such an underwhelming Natural Environment
White Paper for England (4). There is however one person that
saw it differently. George Monbiot, in his column for the Guardian, wrote
(5): Is it really a step towards rewilding?
The White Paper makes no mention of "restoration zones",
but see later. There is, though, this commitment (see 13 in Annex 1 (6): The “multiple benefits” are of course the unbending dogma of British conservation that wildlife has to coexist within farmed landscapes, and is never given space of its own where farming is removed. Hence the drivers for change given in the White Paper are the usual incentives directed to extracted land of agri-environment schemes, although there is some additional funding for a first round of Nature Improvement Areas, albeit allocated on a competitive basis (7). These Nature Improvement Areas are a nod to the Ecological Restoration Zones recommended in the Lawton report, a review of England’s wildlife sites and the connections between them (8). But why the change of name to the seemingly less demanding Nature Improvement Areas?
We always have to be mindful of the erosive conceptual
slippage that characterises our conservation industry, continually
dragging everything to the 'brown-pat' sameness of managed
(grazed) landscapes with
less lows, but with no highs. As we know, the conservation industry is
quite happy to overlook the real meaning of words such as natural, rare,
precious. Thus while ecological restoration is mentioned in the White
Paper, it is obviously too scary a concept for it to be allowed to embed
in the public’s mind through having areas called Ecological Restoration
Zones! The context of ecological restoration in the White Paper is found
in an exposition on creating ecological connectivity in fragmented
landscapes (cores, corridors, stepping stones) but which has no reference
to the Pan European Ecological Network model (9) from which it derives. It
is this that Monbiot must have been pointing to
(see page 18 (6)):
Again, there is a potent evocation of natural systems in
the use of the term “ecological functions” but we can see how
underwhelming this “restoration” will be by what examples are given in the
White Paper (see section 2.13 (6)):
These are the “usual suspects” that tinker with farming
systems on the back of agri-environment subsidies so that there are less
lows, no highs, and the mostly uniform sameness of a cultural landscape. I
wonder, also, how many people know anything about the IBDA pilot areas?
There’s one in each of the regional biodiversity partnership areas, their
role to provide
a means of coordinating the work of a range of UKBAP-driven conservation
initiatives being implemented within a fixed area (10)
but Natural England were so worried about the potential for subsuming of
their IBDAs with the now named Nature Improvement Areas, that they said
this at their Board meeting last September (see 4.1.2 (3)):
Getting back to Monbiot’s article, he reaches into recent
history to the Edwards report, a national parks review panel that reported
in 1991, and which advocated restoration in national parks (11):
Monbiot believes that while Governments may thus have been
talking about areas of ecological restoration for 20 years, that the White
Paper is the first time it has been turned into a “concrete proposal”. He
expands on this by saying (5):
The Edwards report lends support to Monbiot’s aspiration, as
it went even further in Recommendation 6.3, where it proposed the
following (11): It would however be wrong to suppose that no other proposals have been put forward since then. In the year after the Edwards report, Government endorsed the proposal for experimental ‘wilder areas’, and the Council (now Campaign) for National Parks subsequently examined the recommendation as part of a wider range of options for enhancing the wilderness qualities of the Parks. Funding was secured for a Policy Officer who undertook a literature survey, detailed research in six of the national parks, and held consultation meetings with National Park Authorities, statutory nature agencies and NGOs. The potential impacts of creating wilder areas on wildlife, public enjoyment, landscape and economic and social issues were investigated, and a report and recommendations on implementation, entitled Wild by Design, was published in 1997 with a seminar held in Newcastle upon Tyne in the following year (12). It is an interesting report, with a sense of genuine inquiry not yet throttled by contemporary conservation dogma. Thus in capturing the idea of a sense of wilderness, the report recognised that the main attributes of wilder areas were that there was a lack of obvious human management or intensive productive use. A distinction was then made between near-natural and semi-natural areas, where in the former, natural processes were encouraged to maintain the diversity of habitats, and the vegetation was free to vary naturally with variations in the physical environment. In contrast, semi-natural habitats arose from agricultural or forestry use.
In
terms of the creation of wilder areas, two approaches were given: It was noted that some of the perceived qualities of the semi-natural areas had been eroded by human activities, such as the enclosure of open land and the proliferation of fencing, intensification of use or improvement of the land, planting of non-native woodland, canalisation of water courses, and inappropriate physical developments. It ventured that it could be possible to enhance the sense of wildness and improve the quality of experience by removing or making changes to some of these, as well as beginning the process of ecological restoration.
On promotion of areas where ecological process could be
paramount, it noted that there were surprisingly few areas in England and
Wales that had been left totally without management over long periods, and
that the majority of places that had been left to develop naturally had
done so incidentally because of their inaccessibility or low agricultural
potential, or as a by-product of their principal use. After giving some
examples, which gave opportunity for study of this approach to wilder
places, the report concluded that:
What, however, would
be the incentive for private landowners in the national parks to grasp
such a "challenge"? It was argued then in the report, that such a public
policy could be supported by agri-environmental schemes – the same
argument used in the current White Paper. However, the contemporary
indication is, especially in the uplands, that apart from reducing grazing
levels, agri-environmental schemes, which are solely in the gift of
Natural England, are designed to keep landscapes farmed
rather than given over to true ecological restoration. We can get an
indication of how the "challenge" in Wild by Design was regarded, in what is
principally a private ownership of land in national parks, from the
Management Plan from 2003 of the Northumberland National Park (13): Have we have gone backwards in policy terms? So what has changed over the years since Wild by Design, and what will change in the future? To my knowledge, no one has taken up the “challenge” of Wild by Design in any of our national parks. In policy terms we have gone backwards, as there is no wording in the White Paper that looks at ecological restoration in the terms that Monbiot, the Edwards report and Wild by Design advocate - the withdrawal of farming and other forms of commercial exploitation - nor does it appear in the additional information given about Nature Improvement Areas (7). I don’t see any true ecological restoration on a large scale happening any time soon until it is recognised that it is only possible where the burden of exploitation of the land is taken off. That will only happen within public ownership, as is hinted at in the Northumberland National Park Management Plan – “large-scale changes in …land ownership” – and which is the reality in protected area systems of N. America and much of Europe. Ecological restoration doesn’t have to be seen solely in relation to our national parks, but it is the case that there are areas of publicly owned land within them. I have pointed to England’s Public Forest Estate (PFE) as a potential resource of public land for ecological restoration (England's Public Forest Estate - public ownership now and for future generations (14)) and you may not be surprised that 66% of the New Forest National Park’s area of 571km² is in the PFE. That is exceptionally high, but there are other national parks with significant areas of the PFE, such as the North Yorkshire Moors National Park with 13.5% of its area of 1,436km², Northumberland National Park with 12% of its 1,049 km², and about 11% of the Lake District National Park’s 2,292km2. I should also point out that a whacking 23% of the Northumberland National Park is taken up by the Ministry of Defence’s Otterburn Training Ground, which raises the proportion of land in public ownership in that park to 35% or 36,715ha, and so maybe we don’t necessarily need that “large-scale changes in …land ownership” after all, just the political will and the policy to take up the “challenge” from Wild by Design on that publicly owned land in the national park area. There are only a few hundred hectares of the PFE in the Peak District National Park, found around the Hope Woodlands and the Goyt Valley. The biggest landowners in the 1,438 km2 of the Park area are the National Trust which owns 12% (17,507ha) and three water companies which own 11% (16,943 ha) (15). Surprisingly, the Peak District National Park Authority itself owns 5% (6,957 hectares) which includes 394ha of The Roaches, 524ha of the Stanage/North Lees Estate, and 2,700ha of the Eastern Moors Estate (the Moors of Totley, Ramsley, Big Moor, Clod Hall, Jack Flat and Leash Fen). The latter Estate was bought by the Authority with a grant of £350,000 from the National Heritage Memorial Fund. What gets my attention is that there is a large block of about 5,500ha of contiguous moorland on the eastern edge of the Park that is in public ownership, either of the Peak District National Park Authority or Sheffield City Council, or in the beneficial ownership of the National Trust (see map in (15)). This includes the Eastern Moors Estate and the Stanage/North Lees Estate of the Park Authority; the 790ha of the National Trust’s Longshaw Estate, purchased from the Duke of Rutland by public subscription in 1927 and presented to the Trust; the 890 ha of Sheffield City Council’s Burbage, Houndkirk and Hathersage Moors that were acquired by the former Water Committee in the 1930’s when the Council had responsibility for the City’s water supply; the 180ha of Blacka Moor that was bought by the Graves Charitable Trust and then covenanted as a gift to the people of Sheffield in 1933; and a 359ha part of Hallam Moor also owned by Sheffield City Council.
It would seem that this large area of moorland edge could
provide a great opportunity to rise to the “challenge” in Wild by Design.
I have looked at the Peak District National Park Management Plans, and
found this in the Plan for 2000-05 (16):
However, I can find no reference to a reversion to nature,
or any policies that come anywhere near it, in the follow-on Plan for
2006-11 (17). Instead, there is a harking back to a duty in the Wildlife
and Countryside Act 1981 for national parks
(18):
Natural beauty was a central concept in the National Parks
and Access to the Countryside Act 1949, the legislation for the setting up
of National Parks and Areas of Outstanding Natural Beauty. Adrian Philips,
a Vice President of the Campaign for National Parks gave a speech (which
he encapsulated in an essay) for an event in 2009 to mark the achievements
of the Act. He concluded that, looking back, the Act had some major
shortcomings. It split nature conservation from landscape protection and
its enjoyment; it failed to address the problems created by farming and
forestry for landscape, wildlife and heritage; and the central concept of
“natural beauty” was not helpful. On the latter, he wrote (19):
So what use does the Peak District National Park make of
this mapping of “natural beauty”? The Management Plan 2006-11 says that these
areas of land are referred to collectively as the “Natural Zone”, and the
criteria used in their mapping was that they are (20): Planning and development control is a function of national parks, and the zoning appears in the Proposals Map for the Peak Distinct National Park Local Plan (21) and with an associated policy that restricts physical development, but says nothing about land use (22). Thus while the contiguous block of moorland on the eastern edge of the Peak District appears to be in this “Natural Zone”, we can gauge the extent of the aspiration that the Peak District National Park Authority has for this land through the fact that it is solely about control of physical development. The reversion to wild nature of ten years ago, probably inspired by the Wild by Design report, has gone. What do we know about the parcels of land that make up the contiguous block of moorland? Blacka Moor was probably the only place on the moorland edge where people could get an authentic experience of wildness in the absence of it being tainted by farming. In that sense, it had been meeting the “challenge” in Wild by Design for nearly 70 years. However, Sheffield City Council acted in an appalling and disgraceful way when it shrugged off responsibility for maintaining that wild characteristic of Blacka, the decision taken in July 2001 to lease it off to Sheffield Wildlife Trust (see Blacka Moor in peril from the conservation professionals (23) Four strands of barbed wire - a Blacka Moor update (24)). My colleague, Neil Fitzmaurice, eloquently if sadly describes the loss of that wildness since Sheffield Wildlife Trust took over (25).
This shrugging off of responsibility also characterises the Peak District
National Park Authority and its
landholdings. The proposal to sell or lease
a number of sites owned by the Authority arose through a review of assets
in the Asset Management Plan 2005 (26). The overall aim of the
review was to “achieve a significant rationalisation of the property
portfolio” through “disposal of interest”.
Out of this came proposals about the Eastern Moors Estate that sought a
potential partnership arrangement with a view to it seeking extra
resources and/or reduction in management costs,
but also looked at the option of retaining the management of the Estate - sale
of the Estate would have run foul of the need to have paid back the
proceeds to the National Heritage Memorial Fund, even if they were minded
to approve it. In recognition of the reality of contemporary agri-environment
schemes, the Authority noted the ability to maximise income from
Higher Level Stewardship (HLS) scheme funding from the Estate if they
retained its management, but this would of course also be a draw for any
partnership application. Thus in a “beauty
contest” the Authority received formal business case tenders in
October 2008 from the RSPB & National Trust; and Derbyshire & Sheffield
Wildlife Trusts. The Moorland Association & Heather Trust did not pursue
their initial interest. At a meeting of the Services Committee
of the Peak District National Park Authority
in June
2009, it was resolved that (27): The lease for the Eastern Moors Estate was eventually signed this year on 24th January, but before then the Eastern Moors Partnership, as the RSPB/NT now were calling themselves, began a process of consultation in 2010 on the management of the Eastern Moors Estate. The partnership also threw in consultation on the future management of some moors owned by Sheffield City Council, Burbage, Hathersage and Houndkirk, much to the puzzlement of local people. The reason has subsequently become clear after a letter surfaced that was written in December 2009 by Mike Innerdale (General Manager – Peak District NT) on behalf of the Eastern Moors Partnership, and thus only a few months after they won the “beauty contest” (28). The letter was to David Howarth of Kier Asset Partnership Services, a private company contracted in 2009 for seven years at a cost of £55m to Sheffield City Council (SCC) and which “offers a ‘total property solution’ to organisations with large property holdings and specialise in local authority asset management” (29). There’s that “asset management” again! The letter revealed that a meeting had taken place between them in 2009 (other attendees where Mary Bagley, Director, and Nick Sellwood, of Parks and Countryside, SCC, and Harry Bowell RSPB (30)) to discuss the long term future of Burbage, Hathersage and Houndkirk Moors; that there would be a deal on shared letting of grazing on these moors and the adjacent National Trust land of Longshaw Estate; that the vision developed for the Eastern Moors estate could be replicated on the Sheffield moors; that the wider Sheffield Moors would be guided by a “visionary” Public Lands Partnership (SCC, PDNPA, NT, RSPB, Sheffield Wildlife Trust and Natural England); that they would take the income from HLS obtainable on the Sheffield moors; and that they would include stakeholder engagement for the Sheffield moors with that on the Eastern Moors Estate, but they “would only be able to do this for SCC if there was some form of guarantee that the Eastern Moors Partnership would be able to be expanded over the SCC land” (28).
The latter stipulation was not revealed in a report on the
Sheffield moors by David Howarth of Kier Assets that was given to a closed
meeting of councillors of South West Community Assembly in February this
year (31) and was then tabled in the open for the first time at the public
meeting of the South West Community Assembly on the 31 March (32). The
report revealed more back door deals: thus the grazing tenancy on the
Sheffield moors had been terminated on 25th March 2010 and replaced with a
short term Farm Business Tenancy to the National Trust for 18 months from
25 March 2010 to 29 September 2011 (33). This was approved under the
delegated powers of the Director of Property and Facilities Management,
and thus independent of any public scrutiny. In addition, another document
dated November 2010 from Mike Innerdale (NT) and Roy Taylor (RSPB) of the Eastern Moors Partnership to David Howarth
came to light, which purported to explain how the consultation process had
been used to shape their thinking on the
future management of the Eastern Moors Estate. It was however another
pitch to take over the Sheffield moors (34):
The Sheffield Moors Partnership and its vision for the
Sheffield moors were of course inventions of the Eastern
Moors Partnership (NT/RSPB) (see Appendix 2 in (34)) and evidence of their cosy
relationship with David Howarth of Kier Assets and Sheffield Wildlife
Trust (33). We would not know much about this, and all the shabby
dealings, if Neil Fitzmaurice had not tracked down documents using Freedom
of Information. As Neil says (35): There is an inexorable offloading of public land on the eastern edge of the Peak District to the conservation industry: The Roaches (36) and the Stanage/North Lees Estate (37) of the Peak District National Park are likely to be next in this managing of assets, but it is also part of the wider issue of the offloading of state responsibility for wild nature to the conservation industry that has been going on for much longer, and which the Natural Environment White Paper is just another example. However, we can already hear the conservation industry squeal about the potential loss of agri-environment scheme payments that bankroll this expansionism (38, 39) as there are proposals to reform the second pillar of the EU's Common Agricultural Policy, and give support only to “active farmers” (40). Take away the funding of the tinkering with farming that the conservation industry relies on, and then maybe there will be serious consideration of the “challenge” in Wild by Design on publicly owned land, with public authorities accepting their responsibility for public land to provide a home to wild nature, as well as an experience for people of the freedoms of wildness. Mark Fisher 28 June 2011 (1) Conservation Value of Roadless Areas for Vulnerable Fish and Wildlife Species in the Crown of the Continent Ecosystem, Montana, John L. Weaver, Wildlife Conservation Society Working Paper No. 40, April 2011 (LARGE FILE – 24Mb) (2) Jarman, D. 2009. Mapping Wild Land – The Fatal Flaws. Pages 17-18 in Wild Land News, Magazine of the Scottish Wild Land Group, Spring 2009 www.swlg.org.uk/72_-_Spring_2009.pdf (3) Confirmed minutes of the twenty second Natural England Board Meeting on 30 September 2010 www.naturalengland.org.uk/Images/Confirmed%20Sept%202010%20Board%20Meeting%20Note_tcm6-26516.pdf (4) Natural Environment White Paper, DEFRA www.defra.gov.uk/environment/natural/whitepaper/ (5) Environment white paper is a step in the right direction: The government is beginning to respond to the environmental crisis but the real test will be its wider green policies, George Monbiot, Guardian 7 June 2011 www.guardian.co.uk/environment/georgemonbiot/2011/jun/07/environment-white-paper? (6) The Natural Choice: securing the value of nature, HM Government June 2011 www.official-documents.gov.uk/document/cm80/8082/8082.pdf (7) Nature Improvement Areas, DEFRA www.defra.gov.uk/environment/natural/whitepaper/nia/ (8) Making Space for Nature: A review of England’s Wildlife Sites and Ecological Network (the “Lawton Report”) DEFRA September 2010 http://archive.defra.gov.uk/environment/biodiversity/documents/201009space-for-nature.pdf (9) Joint Secretariat for the Pan-European Ecological Network, European Centre for Nature Conservation www.ecnc.org/programmes/green-infrastructure/joint-secretariat (10) Doing more for nature - Integrated Biodiversity Delivery Areas, Natural England (11) Edwards, R., 1991. Fit for the Future. Report of the National Parks Review Panel, Countryside Commission, CCP 334 (12) Loat, E., 1997. Wild by Design in the National Parks of England and Wales. An in-depth exploration of the potential for the creation of wilder areas in the national parks of England and Wales. Council for National Parks (13) A secure future for the land of the far horizons. Northumberland National Park Authority Management Plan, 3rd Review Framework Document, March 2003 www.nuleader.eu/nationalparkmanagementplandocument.pdf (14) England's Public Forest Estate - public ownership now and for future generations, Self-willed land February 2011 www.self-willed-land.org.uk/articles/england_pfe.htm (15) Fact Sheet 1: The Peak District National Park www.peakdistrict.gov.uk/factsheet1-peakdistrictnationalpark.pdf (16) Peak District National Park Management Plan 2000-2005 www.peakdistrict.gov.uk/manplan.pdf (17) Peak District National Park Authority Management Plan 2006-11 www.peakdistrict.gov.uk/npmp.pdf (18) Wildlife and Countryside Act 1981 CHAPTER 69 http://www.legislation.gov.uk/ukpga/1981/69 (19) Adrian Phillips, A. 2009. Landscape – The Maturing of an Idea over 60 years. Essay for November Landscape conference – ‘60 years on: how can we maintain our distinctive landscapes in times of change?’ Natural England, November 2009 http://www.naturalengland.org.uk/Images/Adrian%20Phillips_speech_tcm6-15764.pdf (20) Definition of the Natural Zone: Appendix 4, Peak District National Park Local Plan (Adopted March 2001) www.peakdistrict.gov.uk/appendix4.htm (21) Proposals Map, Peak District National Park Local Plan (Adopted March 2001) www.peakdistrict.gov.uk/proposals-map-txt.htm (22) Policy LC1: Conserving and managing the Natural Zone, Peak District National Park Local Plan (Adopted March 2001) www.peakdistrict.gov.uk/chapter3.htm#LC1 (23) Blacka Moor in peril from the conservation professionals, Self-willed land December 2005 www.self-willed-land.org.uk/articles/blacka_moor.htm (24) Four strands of barbed wire - a Blacka Moor update, Self-willed land March 2007 www.self-willed-land.org.uk/articles/barbed_wire.htm (25) Blacka Moor http://theblackamoorsite.blogspot.com/ (26) Eastern Moors Estate Potential Partnership Options (PM7293/A/B/MC), Services Committee, Peak District National Park Authority 5 June 2009 http://resources.peakdistrict.gov.uk/ctte/services/reports/2009/090605Item5-1.pdf (27) Minutes, Services Committee Meeting 5 June 2009, Peak District National Park Authority www.peakdistrict.gov.uk/090605-mins.pdf (28) Burbage, Hathersage and Houndkirk Moors and Eastern Moors Partnership, Letter to David Howarth, Kier Group, Sheffield, from RSPB/NT 15th December 2009 (29) Kier Asset Partnership Services Ltd. www.kier.co.uk/developments/company.asp?co=120 (30) RE: Plans to Dispose of Land in Peak District National Park, Email from David Howarth to the Director of Property and Facilities Management, SCC, 11 March 2011 (31) South West Community Assembly Members Briefing Paper Meeting Notes February 2011 www.whatdotheyknow.com/request/64145/response/178547/attach/2/TB%20Notes%2010th%20Feb%202011.doc (32) South West Community Assembly Meeting Agenda 31 March 2011 (33) Burbage Houndkirk and Hathersage Moors, David Howarth, Kier Asset Partnership Services 31st March 2011 (34) Summary Report to Sheffield City Council on the Public Consultation on the future management of Burbage, Houndkirk and Hathersage Moors, Mike Innerdale (National Trust) and Roy Taylor (RSPB) as representatives of the Eastern Moors Partnership November 2010 (35) In Bed Together, Blacka Moor 10 April 2011 http://theblackamoorsite.blogspot.com/2011/04/in-bed-together.html (36) The Roaches Estate, Peak District National Park www.peakdistrict.gov.uk/roaches-estate (37) Authority to seek new partner for Stanage and North Lees, Peak District National Park News Release 20 April 2011 www.peakdistrict.gov.uk/index/news/news-display-page.htm?id=24802 (38) Farmland wildlife under threat, Wildlife Trusts 24 June 2011 www.wildlifetrusts.org/index.php?section=news&id=3755 (39) Time for the CAP to step up for the environment, RSPB Campaigns http://campaigning.rspb.org.uk/ea-campaign/clientcampaign.do?ea.client.id=13&ea.campaign.id=10495 (40) The common agricultural policy after 2013, EC Agriculture and Rural Development http://ec.europa.eu/agriculture/cap-post-2013/index_en.htm url:www.self-willed-land.org.uk/articles/nature_improvement.htm www.self-willed-land.org.uk mark.fisher@self-willed-land.org.uk |