Concerns about the validity of statements on the condition of SSSIs in Scotland made by members of Environment LINK

Review and comment on a case study presented by Kirsty Macleod at People TOO conference, Perth

James Irvine

Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire
Editor, www.land-care.org.uk

Filed 17 Nov 04
©www/land-care.org.uk

Note: The editor would like to make it clear that, while this paper is based
on Kirsty Macleod's presentation, this article
contains additional comments by the reviewer.

On the 5th May 2004 the Scottish Parliament voted unanimously to pass the Nature Conservation Bill which impacts on biodiversity, Sites of Special Scientific Interest (SSSI's) and wildlife crime (1). The comments made in the present paper are confined to SSSI's.

According to the Scottish Executive for Environment and Rural Affairs Department (SEERAD), SSSIs are designated solely on scientific grounds. If that is indeed the case, then assurances need to be forthcoming as to:

the quality of the science,

the role played by Scottish Environment LINK (LINK) and Scottish Natural Heritage (SNH) in procuring the evidence, and

the scrutiny which the science and its procurement received from the Scottish Parliament.

Sarah Boyack MSP, chair of the Environment and Rural Development Committee which primarily scrutinised the Bill, allegedly concluded that

"During the passage of the Bill we learned of the poor quality of many of our SSSI's. Attention must be given to them"

But Kirsty Macleod, Director and founder of PEOPLE TOO (Figure 1) wanted to know:

what is Sarah Boyack's statement based on?

What is the scientific justification for it?

Did Sarah Boyack - or any of her research staff - bother to check the evidence that was put before her committee?

Figure 1:

Kirsty Macleod presenting her paper at the conference

(Photo ©Kimpton Graphics)

Data from SNH indicates minimal damage to the quality of Scottish SSSIs

As far as SNH is concerned the only publicly available data on damage to SSSIs that it submitted to the committee is to be found in SNH Annual Reports (2). Kirsty Macleod told the conference that, when she analysed these reports, she found that between 1992 and 2003, only 8,230 hectares (0.008%) of the whole SSSI coverage in Scotland were recorded by SNH as damaged in some way. Of that tiny percentage, 60% is classified as short term damage which is defined as likely to recover in three years (3).

To date SNH only records known cases of direct damage to SSSIs. It is currently assessing the condition of Scotland's SSSIs by carrying out surveys. Although the results of this monitoring exercise will not be published until next year, SNH have already stated that

"in most cases we find the sites in a favourable condition" (4)

The first 5 years of SNH's Site Condition Monitoring Programme ends in 2004.

So where does the evidence come from that SSSIs in Scotland are in decline, and are in need of greater protection?

The only quasi-factual case for more protection on SSSIs can be traced back to certain members of the organisation called Scottish Environment LINK (LINK) (5). It is a political lobby group for its member organisations which are 36 in number. They belong to the voluntary sector. The type of member ranges from the Royal Society for the Protection of Birds (RSPB), the National Trust for Scotland (NTS), the Ramblers Association, Friends of the Earth, Scottish Wildlife Trust, the Scottish Raptor Study Group, Soil Association (Scotland), Butterfly Conservation (Scotland), WWF (Scotland), etc.

LINK is funded by subscriptions (e.g. large organisations with a Scottish income of £2million or more pay a fee of £5,324 per annum) and by grants from SNH, the Scottish Executive Sustainable Action Fund, the Community Fund, WWF Scotland and the Esmee Fairbairn Foundation, the Big Lottery Fund, and Awards for All (5).

"LINK is especially grateful to SNH whose Board in December 2003 renewed a three-year grant for 2004 to 2007 which will contribute up to 28.97% per annum of LINK's forecast core costs during that period." (5)

In August 2001 a 12 page expensively produced glossy pamphlet bearing the logos of 6 of LINK's members entitled "Time to Act - Saving Scotland's wildlife" - appeared (6). It refers to the full complement of Scotland's 1450 SSSIs (rounded up in the pamphlet to 1500). The content of the pamphlet is based on a Technical Document produced by the same 6 members of LINK, also in 2001 (7).

For the sake of brevity the group of 6 members of LINK who produced the pamphlet will be referred to here as "Lobby Group 6", as LINK disowns the pamphlet and the technical document as being one of their publications, as indeed does SNH. When Land-Care asked LINK about the pamphlet (and the document on which it was based) we were advised to contact RSPB Scotland, who kindly sent us both the pamphlet and the document.

The pamphlet makes the following bold statement concerning SSSIs:

"At present SNH only records known cases of direct damage to SSSIs. There is no statutory requirement for the ongoing monitoring of the condition of SSSIs in Scotland, so there are no official statistics to show how they are faring.

"Studies carried out in 1996-1997 by the government's conservation advisors in England show that around 45% of England's SSS|s are in poor condition. No similar Government research has been carried out in Scotland. However, in 2000, a partnership of voluntary conservation bodies arranged a survey of 40 randomly chosen SSSIs in Scotland and discovered that more than half were in a poor condition"

To emphasise their conclusion the authors included in their pamphlet the pie-chart shown here as Figure 2.

Figure 2:

SSSI condition survey in Scotland 2000
according to a pamphlet produced by 'lobby group 6'.

Reproduced from
"Time to Act - saving Scotland's wildlife "(see reference 6)
The present article refers to the authors of this pamphlet as representing Lobby Group 6

The claims and statements made in the pamphlet by Lobby Group 6 require comment. For example it states:

"Studies carried out in 1996-7 by the Government's conservation advisers in England show that around 45% of England's SSSIs were in poor condition"

Referring back to their main document (7) Land-Care found that the only references given for such a statement were to English Nature, Friends of the Earth and Joint Nature Conservation Council websites; none of which on current consultation carried any such information that Land-Care could find. However, a reference was given to an earlier RSPB publication in 1998 (produced by their HQ in England), which also took the form of a technical document. It was entitled "Land for life" (8). Does that mean that RSPB considers itself to be the "Government's conservation advisers in England"?

Be that as it may, the RSPB 1998 technical document emphasises the difficulties in agreeing what standards should be used in monitoring conservation areas. Indeed, as far as Land-Care could ascertain, the only reference given in the Lobby Group 6 2001 technical document as to the methods used for assessing site condition was to an internal SNH document that is not available to the public (9). As far as Land-Care is aware, there is still no general agreement as to the methodology of assessing conservation sites.

Remarkably the data contained in the Lobby Group 6 technical document (7) - and used to produce the alarming statements made in the pamphlet "Time to Act" includes:

"anecdotal accounts from area staff such as the RSPB, SWT, NTS, Plantlife and SNH."

and

"published information on SSSI damage and loss, reported by SNH as well as information published on the internet by organisations such as Friends of the Earth"

In Land-Care's view, here can be little wonder that the information gleaned from such sources based on dubious methodology was confined to a technical document and a glossy pamphlet, as presumably no self respecting professional asked to carry out a peer review of such a paper would find it acceptable for publication in a scientific journal of standing.

SNH, although funding LINK, says that LINK is a separate organisation from SNH. Yet the deputy chairman of SNH, Mike Scott, is one of the authors of the document (wearing his Plantlife hat as a member of its advisory Board). Roger Crofts is also a Board member of Plantlife, but remember he spent many years at SEERAD and then as Chief Executive of SNH and is now a board member of the Scottish Agricultural College (10).

So, although SNH says that LINK is a separate organisation from itself, SNH has plenty of opportunity to influence the activities of LINK. There does appear to be a cosy coterie of influential people who, through there involvement with certain lobby groups, have a disproportionate influence on how Scotland's environment is managed. On top of that there is much concern as to the quality of the propaganda that they generate in the name of science.

Analysis of the claims of Lobby Group 6 and what was presented to MSPs when the Nature Conservation (Scotland) Bill was being considered

In effect the pamphlet (6) engendered considerable publicity when the Nature Conservation (Scotland) Bill was introduced (11). After all it did say that as many as 45% of sites of Special Scientific Interest (SSSIs) in Scotland, as in England, were in an unfavourable and deteriorating condition. Alarming stuff! But was it true?

But let us analyse what Lobby Group 6's Technical Document "SSSIs condition assessment, Scotland 2000" actually says and who says it (7).

According to Land-Care's reading, the field work and the preparation of the report was carried out by RSPB ecologist, Julie Ellis. The report states that the other five authors had functioned as supervisors, with two from RSPB (one from Scotland and one from south of the border), one from the Scottish Wildlife Trust (SWT) and one from the National Trust for Scotland (NTS) and one from Plantlife (who just happened to be the deputy chairman of SNH).

Quite part from apparently misleading the reader in the Introduction by a scaremongering statement about the dire situation in England (based on the flimsiest of evidence of essentially RSPB's own making), the weaknesses of the report can be illustrated by quoting from it:

"A a time when the Scottish Executive is considering proposals for improving the protection and management of SSSIs it is important to gain an understanding of how well these sites are meeting nature conservation objectives. In the absence of any published government statistics on the condition of SSSI's in Scotland, a number of voluntary conservation bodies have commissioned their own study"

"The statutory conservation body, SNH, is responsible for identifying, designating and monitoring SSSIs. Publicly available reports on the condition of SSSIs have been limited to highlighting new damaging activities with no information about ongoing deterioration through inappropriate management or neglect. Studies of sites in England (RSPB, 1998, EN 2000) have been carried out to assess their condition and have shown 45% of sites there as being in unfavourable conservation status".

Land-Care's comment here is to ask why SNH, with its massive government funding and some 700 staff, have not got round to addressing this alleged priority. As the report itself states, SNH has not as yet determined just how such an assessment should be done. Yet the RSPB and its hangers-on decided that they could do it with just one ecology field worker.

"Condition assessments involved surveying quadrats (both 1m x 1m and 2m x 2m depending on the habitat and impact being studied) as a sample area of the site. Quadrats were temporary and unmarked. A minimum of nine quadrats per site were studied with vegetation structure and species recorded. Study SSSI area varied from 0.5 ha to 10232 ha. The number of quadrats surveyed was higher with the larger sites to try to give an accurate reflection of the habitat across the site.

However its was noted that time constraints led to fieldwork being out with approximately a day per site. Without the combination of these constraints and lone fieldworker health and safety issues a more rigorous survey of the upland sites would have been possible"

Other comments in the report, describing the methodology used, are also a cause for concern.

"Information regarding damaged sites was pooled from various sources. These included anecdotal accounts from area staff or organisations such as the RSPB, SWT, NTS, Plantlife and SNH. Published information was also used on SSSI damage and loss, reported by SNH as well as information published on the internet by organisations such as Friends of the Earth"

That does not amount to substantive data.

The report assures us

"The selection of a random sample of sites, representative of the different habitats in the Scottish SSSI series, was considered to provide an objective way to assess the extent of the favourable/unfavourable condition."

But, as quoted above, the report itself admitted serious constraints as to why this could not be so, at least in terms of the upland sites (lone field worker, time constraints and health and safety).

But only 50 sites out of 1450 were randomly selected by computer-generated random numbers as shown in Table 1 of the Report to cover 6 types of habitat: 17 heathsite, sixteen bog/mire sites, six coastal sites. 6 grassland sites three woodland sites, two open water sites and nil from the 11.6% of Scottish SSSI area covered by other habitats

Habitat	percentage of Scottish SSSI area covered by this habitat	No. of study sites selected with this habitat predominant
Heath	29.9	17
Bog/mire	26.8	16
Coastal	11.3	6
Grassland	9.9	6
Woodland	5.0	3
Open water	3.5	2
Other	11.6	0
Total	100	50

Table 1:
Number of sites to be surveyed in each habitat group

Reproduced from
"Sites of Special Scientific Interest: Condition assessment". A technical Document. Bain et al.(7 )
This article refers to the authors of this Technical Report as representing Lobby Group 6

But time constraints led to less than 50 sites being surveyed. Thirty eight sites were surveyed by the project officer with the remaining sites assessed on existing data only. These data were incomplete in some cases and did not follow the SNH guidelines for assessment (which it is understood have not yet been finalised).

Surely this can hardly be "considered to be an objective way to assess the extent of the favourable/unfavourable condition". The sampling is much too small to draw anything but the most preliminary of conclusions. It was not enough to justify the release of publicity pamphlets aimed at impressing the public and politicians under the guise of science at the time when the Nature Conservation (Scotland) Bill was being considered.

Nevertheless the report states in its summary:

"The problems identified in the case examples appear to be reflected across the SSSI network. From 40 SSSIs studied across a representative range of habitats it was found that 55% (22 sites) were in an unfavourable condition. Of the sites in unfavourable condition, only 10% (4 sites) were showing significant signs of improvement. Grazing from sheep and deer as well as fire and drainage are among the main threats identified as having caused damage".

As far as Land-Care could ascertain, there were no independent scientists included in the authorship of the report. If any such credible scientist had been asked he/she would surely have refused to put their name to it, on the grounds that the report claimed far more that its content justified - on account of the basic construction being so limited, and the initial premise being so misleading.

As mentioned above, extracting from SNH Annual Reports and Facts and Figures, 1992-2003, it was noted that SNH has indeed 1450 SSSIs. Between 1992 and 2003, only 8,230 hectares or 0.08% of the whole SSSI coverage in Scotland were recorded by SNH as damaged in some way. Of that tiny percentage, 60% is classified as short term damage which is defined as likely to recover in 3 years.

Also, as already mentioned, SNH is only now assessing the condition of Scotland's SSSIs and have already stated that in most cases they found the sites are in a favourable condition (4). It is understood that the results of this monitoring exercise will not be published until next year.

It would therefore appear that the RSPB and its group of 5 associates decided to jump the gun and get in with some striking figures just as the Scottish Parliament was debating the Nature Conservation (Scotland) Bill. Kirsty Macleod told the conference that SNH did not submit in its own name any evidence of damage to SSSI sites in Scotland to the Scottish Parliament (12). Yet, as the report itself states:

"The statutory conservation body, SNH is responsible for identifying, designating and monitoring SSSIs. The condition of SSSIs in Scotland is the responsibility of SNH."

As the Nature Conservation (Scotland) Bill progressed through the Scottish Parliament, three representatives of Scottish Environment LINK (RSPB, SWT and the Woodland Trust Scotland) gave oral evidence to the Environment and Rural Development Committee (chaired by Sarah Boyack) on 12th November 2003 (13). Two of their written submissions and an additional written submission from Environment LINK itself referred to Time to Act - Saving Scotland's wildlife (remember this is not a LINK document) and its claim that the condition of 45% of Scotland's SSSIs were of unfavourable status and were deteriorating. In his oral evidence, however, Lloyd Austin of the RSPB/LINK went further than this and stated:

"The figure of 45% of SSSIs not being in favourable status came from a survey of a sample of about 10% of sites in Scotland that we organised".

Kirsty Macleod told the conference that she then wrote to the Committee Clerk and pointed out that the Time to Act pamphlet referred to a random survey of only 40 out or the existing 1435 SSSIs in Scotland. Forty sites in no way represents a 10% sample of the total SSSIs in Scotland, but 2.8% which could not be considered as being adequately representative.

The Committee Clerk asked Environment LINK to clarify the 10% claim. Kirsty Macleod told the conference that she received an email from Sarah Boyack on 10th December informing her that clarification had now been obtained from RSPB Scotland, a copy of which was attached for her information and was also available in the public domain.

In this supplementary submission (which stated that it was from RSPB Scotland, although he was speaking on behalf of Environment LINK when giving evidence on 12th November) Mr Austin referred to the technical document (7) on which Time to Act was based.

Allegedly for the first time it was made clear that Time to Act only looked at SSSIs designated for their biological interest. It was also admitted that the sample of 40 sites was not really random since SSSIs in the Western Isles were not considered due to logistics. So at least 309 geological SSSIs out of 1436 were removed, leaving 1127. Why then did Time to Act refer to all of Scotland's 1500 SSSIs, Mrs Macleod asked.

But Lloyd Austin had said to the Committee that the sample used to calculate that 45 % of SSSIs were deteriorating was based on a 10% sample, although 10% of 1127 is 113 - not 40.

Mrs Macleod informed the conference that, in his clarification, Mr Austin pointed out that the Technical Document (7) contains two studies, not just one random study of 40 sites. According to Mr Austin the second survey comprised case studies on SSSIs suspected of being (or known to be) damaged and held on the files of RSPB, SWT, NTS and Plantlife. There were roughly 70 sites in this second study. If these are added to the 40 you get 110: which is about 10% of the 1127 biological SSSIs in Scotland.

He added that detailed accounts of these case studies are in Annex 2 of the Technical Document. But there is no Annex 2 in the technical report - indeed the report does not make any mention of such an annex anywhere in the document. When challenged Mr Austin stated that his reference to an Annex 2:

"was an oversight on his part".

The Technical Document (7) refers in its table 4 to a list of examples of damaged Scottish SSSIs collected anecdotally from staff of nature conservation organisations such as RSPB, SWT, NTS, Plantlife and SNH, as well as information published on the internet by organisations such as Friends of the Earth. However, this list lacks specificity, so that it would not be justifiable to link this poorly controlled information with the 40 site visits which formed the substance of the document (albeit on basis of scant data).

In Land-Care's view the claim by 6 members of SNH supported Environmental LINK, stating that

"45% of Scotland's SSSIs were in unfavourble and deteriorating condition"

would be difficult to justify in such a high profile manner.

RSPB appeared to be the main promotors of this alleged misinformation, although the deputy chairman of SNH (but in a different capacity) was party to it.

In this context Land-Care notes that a RSPB-backed advertising campaign in relation to "green" electricity recently fell foul of the Advertising Standards Authority. The Authority adjudicated that the adverts be withdrawn because the claims made were based on evidence that failed to stand up to scrutiny (14).

Conclusion

It is alarming that misleading evidence was allegedly presented by well-funded lobby groups (who have such strong lobbying power at the Scottish Parliament), to MSPs in committee and to the public at large in relation to the introduction of such an important Bill as Nature Conservation (Scotland).

It is also alarming that the screening of evidence presented to the relevant parliamentary committee was allegedly poor.

Even more worrying is the alleged lack of a competent re-assessment when serious deficiencies concerning evidence presented to the Committee was documented in a formal letter to the committee clerk.

References

1. Scottish Executive (2004). Nature Conservation Bill passed. News Release, 05/05/2004

2. SNH Annual Reports - see http://www.snh.org.uk

3. Based on the best assessment that Kirsty Macleod could make from data extracted from tables contained in SNH Annual Reports 1992 -2003

4. SNH (2003). The first 5 year cycle of SNH Site condition monitoring programme ends 2004.
Sitelines: SNH in-house magazine. Summer 2003, p2

5. Scottish Environment LINK.
http://www.scotlink.org

6. Time to Act - saving Scotland's wildlife . Twelve page glossy booklet produced by 6 members of the lobby organisation Environment LINK for promotional purposes. These 6 members are referred to in the present paper as "Lobby Group 6"

7. Bain, C.G., Ellis, J.A., Langston, R., Luxmoore, R., Scott, M. & Sommerville, A. (2001). Sites of Special Scientific Interest - condition assessment Scotland 2000.
Butterfly Conservation, RSPB Scotland, National Trust for Scotland, Plantlife, Scottish Wildlife Trust, WWF. A technical document. Produced by "Lobby Group 6".

8. Langston, R.H.W., Wilkinson, N.I. Renwick, N. & Burston, P.(1998). Land for life. Technical support document. June 1998 wpo/3567. Produced by RSPB

9. SNH (2000). Site condition monitoring guidance folder, McKirdy, A & Shaw, P. SNH internal document (not available to the public).

10. Editorial (2002). Scottish Agricultural College - what is going on?
See SCIENCE Homepage, filed 17 Oct 02, www.land-care.org.uk Click Here to View

11. Edwards, Rob (2003). Wildlife to get tough new protection. Executive to safeguard Scotland's most precious natural havens. Environmental Editor, Sunday Herald: 9th March, 3rd Edition page11.

12. Alleged to be stated in an Email to Kirsty Macleod from SNH Head of Secretariat.

13. Environment & Rural Affairs Committee. Oral evidence on 12th November 2003
http://www.scottish.parliament.uk/business/committees/historic/environment/or-03/ra03-1102a.htm#Col386

14. Editorial (2004). RSPB-backed 'green' marketing scheme censored by Advertising Standards Agency
See ENVIRONMENT Homepage,11 Dec 04, www.land-care.org.uk Click Here to View

Finis

MENU

Concerns about the validity of statements on the condition of SSSIs in Scotland made by members of Environment LINK

Review and comment on a case study presented by Kirsty Macleod at People TOO conference, Perth

James Irvine

Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire
Editor, www.land-care.org.uk

Filed 17 Nov 04
©www/land-care.org.uk

Data from SNH indicates minimal damage to the quality of Scottish SSSIs

So where does the evidence come from that SSSIs in Scotland are in decline, and are in need of greater protection?

Analysis of the claims of Lobby Group 6 and what was presented to MSPs when the Nature Conservation (Scotland) Bill was being considered

Conclusion

©www.land-care.org.uk

References

Further Reading

Other review articles published to date on Land-Care relevant to the People TOO conference: "Who runs rural Scotland?"

MENU

Concerns about the validity of statements on the condition of SSSIs in Scotland made by members of Environment LINK

Review and comment on a case study presented by Kirsty Macleod at People TOO conference, Perth

James Irvine

Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire Editor, www.land-care.org.uk

Filed 17 Nov 04 ©www/land-care.org.uk

Data from SNH indicates minimal damage to the quality of Scottish SSSIs

So where does the evidence come from that SSSIs in Scotland are in decline, and are in need of greater protection?

Analysis of the claims of Lobby Group 6 and what was presented to MSPs when the Nature Conservation (Scotland) Bill was being considered

Conclusion

©www.land-care.org.uk

References

Further Reading

Other review articles published to date on Land-Care relevant to the People TOO conference: "Who runs rural Scotland?"

Teviot Scientific, Cultybraggan Farm, Comrie, Perthshire
Editor, www.land-care.org.uk

Filed 17 Nov 04
©www/land-care.org.uk