| Re: new biodiversity Action Plans discuss Hi Gill,
I don’t think going down to individual races is helpful in most cases except when dealing with some habitat compensation / restoration projects. Although I can see the temptation of using races when trying to protect sites from development if you’re relying on species which are reasonably common. However, I’ve been involved in lots of public inquiries and its hard enough getting agreement on the presence or absence of different species, survey methodologies and what significance criteria to use (don’t mention IEEM criteria or I’ll scream!). If you have to argue the case not only on species but on race as well, the planning inspector will either be confused, think it’s an irrelevant argument between specialists or commit suicide through boredom (not good for your case but a tactic often used by development friendly ecological consultants). I was at an inquiry when an inspector seemed to drop off to sleep after 3 days argument about the distribution of red data book invertebrates and I wasn’t far behind.
Also, think of the poor old planners who have to put in Biodiversity policies in their Regional Spatial Strategies (RSS) and Local Development Documents. Many try valiantly but don’t have much of a clue regarding the value and legislative background of why biodiversity matters to them. I’m dealing with a Sustainability Appraisal of a RSS at the moment and most of the RSS Steering Group hadn’t heard of priority BAP habitats or their responsibilities to Habitats of Principal Importance under the Natural Environment and Rural Communities Act 2006 section 40, so how can they be expected to worry about races when they don’t even understand the basics?
Races should be used at site level when looking at site compensation or restoration, I always consider local provenance, it can be the difference between success and failure e.g. with tidal v freshwater phragmites, but it should be kept out of the planning system as it’s a charter for unscrupulous consultants to bog-down planning inquiries in superfluous detail that planners and inspectors often don’t understand.
Chris |