we set out under KKB Submission to the 4th National Biodiversity Action Plan:-
4th National Biodiversity Action Plan
Response to Draft for Public Consultation. Thank you for the opportunity to consult on the above matter. We would be grateful if the following points could be considered for future drafts.
Whole of government and whole of society approach
· Effective communication and buy-in are critical to delivering the national biodiversity strategy. Increasingly, sectors like agriculture, industry and conservation are becoming more siloed and oppositional as policy and financial pressures increase and mutual understanding decreases. In order to deliver a truly ‘whole of government and whole of society approach’ all sectors of government, business and society need to be included in the delivery of the biodiversity strategy. Effective solutions to biodiversity issues can often emerge from within a community, sector or industry when engagement is meaningful and non-confrontational.
· There is potential to introduce pilot projects that bring different communities and sectors together to deliver tangible on-the-ground solutions to specific issues in areas such as agriculture, energy and community development in a collaborative way. These pilot projects could be used to promote, not just the solution, but the collaborative process that delivered change and models conflict resolution strategies.
Biodiversity Net Gain
· The Plan should set out objectives that enable each sector to achieve Biodiversity Net Gain on new plans and projects. Mandatory BNG has recently been introduced in England and Wales and adopted voluntarily in other areas and sectors. Good quality baseline information is critical to delivering and monitoring BNG along with adequate resources within the consenting authority to review applications and long-term delivery.
· Planning and Development requiring planning permission should be linked to the achievement of good ecological status in associated water courses prior to planning approval and after completion of projects
Communities
· Community empowerment is one of the most effective means of delivering change and is necessary for societal buy-in. Bottom-up initiatives like the All-Ireland Pollinator Plan have proven successful in harnessing community energy by undertaking clear evidence-based, targeted actions on a very specific topic. Similar initiatives could be developed through organisations on the ground once they are adequately resourced to develop targeted strategies. This can can help avoid stagnation in the delivery of top-down policy.
Education and research
· It is estimated that there is as much biodiversity below ground as above ground, but soil ecology and biodiversity is often completely overlooked, outside agricultural fertility parameters. Healthy soils are critical to food production, carbon sequestration, medical treatments and a range of other services that are beginning to be recognised. This is a growing area of research in light of both the biodiversity and climate crises and would benefit from acknowledgement and support within the NBAP.
· Further emphases should be given to delivering sustainable education programmes at Junior, TY and Senior cycles to introduce ecological literacy and ensure that children and young adults have a good understanding of biodiversity issues and actions needed to protect it. Increasingly, more of us are living in urban settings and have lost connections to nature and our basic understanding of food production and other ecosystem services. There is potential to develop projects that link schools with the farming community or other individuals and groups that work with nature. While many programmes, such as Green Schools, have achieved excellent results, there is still significant potential to bring nature and sustainability into schools and the curriculum as a whole.
Resourcing and waste management
· Food production and food waste are critical issue for biodiversity both globally and nationally. Globally we waste one-third of all food produced annually. This equates to approximately 16% of habitable land on the planet. In Ireland, we waste approximately 1 million tonnes of food per annum. By changing this one issue, we could divert the wasted land resources to biodiversity use and reduce GHG emissions from production and decomposition. The Plan clearly acknowledges the devastation impacts climate change will have on biodiversity and the irreversible effects on ecosystems. Targeted programmes to engage communities on the ground to tackle specific issues around food production and waste could be considered for support within the Plan.
· An engaged society, targeted actions and adequate resources are needed to deliver an effective strategy. Funding along with people’s time and energy are all limited resources and should be spent wisely. Ineffective and wasteful spending should be identified within Departments and programmes and re-routed to bodies and programmes that can deliver. Examples of this occur in agricultural schemes where participants are financially incentivised to take actions that have no demonstrated benefits, or in some instances, they have negative effects on biodiversity. These schemes are sometimes developed without the appropriate input from relevant experts and groups that could guide a meaningful programme. In other instances, it can occur where new actions or programmes are trialled but proved ineffective, but continue to be implemented by Departments.
Lessons learned
· Globally and nationally, we have failed to deliver on successive plans and actions to protect biodiversity. Our food, energy and consumption models are broken and need transformative change. Learning is an iterative process and mistakes are part of that process. It’s important that we build in effective review processes, learning from previous successes and failures and change course as required.
