1.  Plantlife—The Wild Plant Conservation Charity is a non-governmental organisation dedicated to conserving Britain's native plants in the wild. The organisation was founded in 1989 and now has a membership of 11,500. Plantlife is a key player in delivering the Government's Biodiversity Action Plan for plants in the UK, through its role as Lead Partner for a total of 74 "priority" fungi and plant species. In England this work is delivered through a unique partnership with English Nature's Species Recovery Programme. Plantlife is also developing strong links with the European conservation community and is a founder member of a network of European plant conservation organisations, Planta Europa. Plantlife welcomes the opportunity to submit evidence to this inquiry.

  2.  Plantlife works closely with the Environment Agency on projects for species of aquatic or marginally aquatic habitats or where water quality or quantity issues have been identified as significant to a species' survival. The Environment Agency is the Contact Point for eight species which are lead partnered by Plantlife; they also have a significant role to play in delivering BAP targets for a further 15 to 20 species (the extent of their involvement with some species is still to be determined).

  3.  Plantlife welcomes the commitment that the Environment Agency has shown to the Biodiversity Action Plan in taking on a Contact Point role for some species and in providing staff time and resources to establish how targets can be integrated into the work of the organisation through Local Environment Agency Plans. Environment Agency is uniquely placed to deliver information about the impacts of water quality and quantity change on aquatic habitats and species. In some cases (for example the project for starfruit, Damasonium alisma, one of Britain's rarest plants) this expertise has been used in a constructive and generous manner.

  4.  However, Plantlife retains serious concerns about the manner and extent of the Agency's engagement with nature conservation.

  5.  The conservation of biological diversity is not mentioned in the seven objectives (set by UK Government) through which the Environment Agency seeks to achieve sustainable development. This is a startling omission for an organisation central to the maintenance of the aquatic environment, including habitats and species for which we have international obligations under the Convention on Biological Diversity, the Ramsar Convention on the conservation of wetlands, and legal obligations through the EU Habitats Directive and UK law.

  6.  This failure to foreground nature conservation is reflected in the limited resources which are currently being made available within the Agency to deliver BAP targets. Whilst resources have been directed at those species and habitats for which the Agency is Contact Point, little or nothing has been offered to other projects where the role of the Agency may be equally crucial, but where they have not volunteered to take the Lead. Thus for many species which are known to be affected by abstractions, pollution or by damaging patterns of land drainage there is little prospect of Environment Agency support (in the form of staff time or direct financial assistance).

  7.  Concerns also exist about the extent of the Agency's responsibilities for maintaining water quality on sites which are important for nature conservation. Whilst EA's obligations on controlled water courses are relatively clear, many important aquatic habitats fall outside of this definition, including some ditch systems and nearly all ponds. (The 1994 Land Drainage Act places a responsibility on Local Authorities and Internal Drainage Boards to manage aquatic environments with regard to their environmental quality; however, in practice these bodies often do not have the expertise, resources or political will for the task.) In addition, the water quality thresholds which are most frequently applied to water courses of all kinds are designed only with human health in mind and do not meet the more stringent demands of aquatic biota. Plantlife believes that Britain's aquatic biodiversity would be better served by an Environment Agency whose powers included responsibility for water quality on all sites of nature conservation interest, with the aim of maintaining and enhancing that interest. Clearly the control of diffuse sources of pollution such as agricultural run-off would require the collaboration of other branches of government as well as the farming and business communities. However, until it is the statutory obligation of one body to identify and take measures to control such pollution in all parts of the country (not just Nitrogen Sensitive Zones) it is unlikely that any positive action will take place to curb this major threat to our wildlife.

  8.  The Agency's powers in relation to the maintenance of water quantity on sites of nature conservation interest are more extensive, including the identification of abstractions which are potentially damaging these sites and the possible refusal or rescindment of licenses. These wider powers are welcome, but staff need to be more aware of them and be encouraged to use them more consistently. Placing a nature conservation objective at the heart of the organisation would, we believe, have a positive influence on this, as would improved resourcing for this area of the Agency's work.

  9.  Finally, Plantlife are concerned about the current relationship between Environment Agency and British Waterways and other bodies responsible for the management of canal systems. Canals are an important aquatic habitat in Britain, particularly for aquatic plants, which have found refuge in them when other habitats have been damaged by drainage, over-abstraction and pollution. British Waterways themselves have no statutory obligation to maintain the quality of the habitats which they manage (outside of the SSSI network); nor do they have the expertise or experience in the management of fresh-water habitats which would make it appropriate for them to have sole responsibility for this. We understand that Environment Agency are also increasingly concerned about the impacts of pond-level falls, water pollution and traffic movement on areas of river which are connected to the canal system. Plantlife believe that EA must be given some regulatory powers over the canal system which would enable them to maintain the quality of the habitats themselves and minimise the impacts of development upon any connected waterways.

  10.  In conclusion, Plantlife believe that the Environment Agency is performing many of its current functions with distinction and courage, and that it has already contributed significantly to the delivery of UK Biodiversity Action Plan. However, nature conservation needs to be made central to the organisation's mission, and resources devoted to taking a positive role in delivering targets for all relevant species and habitats. Plantlife also believes that responsibility for all issues of water quality and quantity affecting biodiversity in the UK should lie with the Agency (as the centre of expertise and the appropriate regulatory body); appropriate levels of additional resources would be necessary to ensure that they could take on this role effectively.

October 1999