ECOS 45 (1) – Protected Area Downgrading, Downsizing and Degazettement (PADDD) in the UK

NIGEL DUDLEY

We know that British protected areas are legally being downgraded, downsized and sometimes degazetted altogether, but without central collection of information, we have very little idea how many sites are involved, and how often this occurs. As the UK attempts to fulfil it’s obligations under the Global Biodiversity Framework, this lack of information is worrying.

The underlying premise of a protected area is that it will be in place for the foreseeable future. The IUCN definition refers to “the long-term conservation of nature”.1 In the last few years, legitimate fears have been expressed about the ability of protected areas to function effectively if ecosystems shift as a result of climate change2 and in consequence whether place-based approaches remain relevant. While it is clear that climate change is causing profound ecological changes, research suggests that intact habitats in protected areas will be both more resilient to these changes and more likely than modified ecosystems to provide useful habitat for species that are shifting their ranges.3 Conservation planners are thinking about how area-based conservation can include temporal response to climate change,4 but the idea that most protected areas should involve a long-term commitment is likely to remain central to conservation philosophy.

“Long term” is often hard to define; governments have a right to change management decisions as discussed below, and many also have regular reviews of status. But whatever the legal situation, the intent of a protected area should be for a multigenerational commitment to conservation.

PADDD refers to legal changes to a protected area’s status.
Photo: Nigel Dudley

Defining PADDD

This is not always the case in practice. Over the last few years, the phenomenon of Protected Area Downgrading, Downsizing and Degazettement (PADDD) has been recognised and defined5 and tracked around the world via the online PADDD Resilience Atlas. As the name suggests, PADDD describes three kinds of changes. Downgrading here means reducing the level of protection; for example, changing the rules to allow more tourist infrastructure, opening a marine protected area to additional fishing, or allowing mining in what has previously been a strictly protected area. Downsizing means slicing away some of a reserve, for a road, settlement, reservoir, etc. And degazettement is a complete change of land or water use so that it is no longer a protected area at all. PADDD is descriptive and value-free. Most PADDD events are damaging to conservation But not all; a decision by the US National Parks Service to open National Parks to collection of traditional medicines by native Americans has been widely welcomed, although it features as a PADDD event on the Resilience Atlas. These are exceptions and most PADDD undermines conservation objectives.

PADDD refers to legal changes – a conscious action by the state. Plenty of other things go wrong in protected areas, including illegal incursions, poor management effectiveness, protected areas established in ways that guarantee them to fail and “paper parks”, legally set up but never really established. These all reduce the effectiveness of a protected area system, but they are not PADDD. More ambiguous are changes that occur because one part of government ignores or overrules another, like a ministry of mining granting exploration rights over an area that a ministry of environment has declared a National Park. These incidents, common in many parts of the world, are also generally labelled as PADDD events although the legal situation is less clear. Because of the clause about legal changes, at present PADDD cannot be applied to privately protected areas or areas managed by Indigenous peoples or local communities without legal status. Perhaps in the future some criteria for applying PADDD in these situations should also be developed.

PADDD is unnerving because it strikes at the heart of what has traditionally been regarded as a cornerstone of conservation, including in some of the world’s best known protected areas.6 The protected area network is supposed to be the framework around which other conservation actions take place; if it is insecure the whole conservation strategy is also threatened.

Biodiversity offsetting has made it easier to damage or destroy protected areas.
Photo: Nigel Dudley

Is PADDD a problem in the UK?

Criticism of the UK protected area network usually focuses on effectiveness; in a country with around 27 per cent of land area nominally in protected areas, biodiversity is still declining fast.7 The extent to which large landscape designations like National Parks and Areas of Outstanding Natural Beauty meet either the IUCN or Convention on Biological Diversity definitions of a protected area has been debated for years.8 But is PADDD also a problem? To a large extent, we don’t really know and this lack of information is illustrative of a major gap in our monitoring.

UK data on the Resilience Atlas is cursory and focuses almost entirely on downgrading linked to potential oil and gas exploration, affecting many of Britain’s marine protected areas.  In another mass assessment, many of the UK National Parks and AONBs were PADD-listed in a global assessment due to threats of fracking.9 While the government has banned drilling within National Parks and SSSIs, AONB do not have the same protection10 and fracking is also in theory allowed at depths of 1200 metres or more in any protected area if drilling takes place outside the borders. In 2022 research for The Guardian newspaper found many protected areas in England overlapping with or adjacent to exploratory licenses.11

Localised and site-specific impacts are not systematically recorded on a national scale. But even a rapid skim of the literature suggests that all three elements of PADDD are present in the UK, and that if anything incidents have been increasing over time.

Losses along the path of the HS2 rail link have gained the most publicity in recent years. While plans have now been scaled down, the original route impacted three Special Areas of Conservation, two Ramsar sites, 33 Sites of Special Scientific Interest, including two National Nature Reserves, and 21 Local Nature Reserves. Additionally, an additional 693 Local Wildlife Sites, which are not full protected areas but play important local and connectivity conservation roles, were likely to be affected. Many of these sites contain rare or endangered species12 and subsequent research suggests that the developers seriously underestimated the wildlife damage that has occurred in phase 1,13 something HS2 disputes.

Other PADD events have to be collected piecemeal from the websites of statutory conservation bodies (where information is variable), from campaign groups or local news sources. For example, large parts of Muston Meadows National Nature Reserve in Leicestershire was de-declared in 2016. Fyfield Down had been a National Nature Reserve since 1956, and lies within the Avebury World Heritage site, but was stripped of NNR status in 2022 because of objections from the new owners. Tarn Moss NNR in Cumbria was downsized in 2023. In South Wales, the Gwent Levels, an ancient landscape, was threatened with a motorway extension and now again from adjacent development. In Scotland, at least 25 National Nature Reserves have been de-declared in the last twenty years, including iconic sites like Ben Lawers, Inverpoly and Rannoch Moor (Scottish Natural Heritage protected area notices of 2011 and 2018). While most of these sites remain SSSIs, and thus formally under protection, SSSIs are also being de-declared, most notoriously at Foveran Links, where part of the dune system was destroyed to make way for a golf course built by Donald Trump.

But information is hard to find. The Joint Nature Conservation Committee admitted that it does not monitor or hold data on SSSIs damaged or destroyed through successful planning applications,14 referring back to the devolved bodies. But these all differ in the way they report (or if they report) changes to SSSIs or other protected areas. Information about private reserves, whether in individual hands or those of charitable trusts, is even less accessible.

There is a worrying lack of information about PADDD in the UK.
Photo: Nigel Dudley

Into the future

Losses could increase further. The UK government introduced biodiversity offsetting in 2011, making it easier to destroy protected areas as long as equivalent sites were established by the developer.15 Offsetting is deeply controversial, because of the difficulty of finding an “equivalent” site in many places and due to evidence that it often does not work well in practice.16

In a small and crowded country like the UK some trade-offs are perhaps inevitable. But it is worrying that we know so little about what is being traded off, how often, by whom and what the consequences might be. A national PADDD database is needed, probably managed by JNCC but with input from all the statutory and major voluntary bodies. Most of the information is already available, but currently hidden and lack of publicity will encourage local and national governments to assume that changes will go unnoticed. A full report on changes over the last twenty years would be a good place to start.

Acknowledgements

Thanks to Hannah L. Timmins and Sue Stolton for comments on an earlier draft.

References

1. Dudley, N. (ed.) (2008). Guidelines for Applying Protected Area Management Categories. IUCN, Gland, Switzerland.

2. Dobrowski, S.Z., Littlefield, C.E., Lyons, D.S., Hollenberg, C., Carroll, C., et al. (2021). Protected area targets could be undermined by climate-driven shifts in ecoregions and biomes. Communications Earth and Environment 2: article 198.

3. Hannah, L. (2008). Protected areas and climate change. Annals of the New York Academy of Sciences 1134 (1): 201-212.

4. Parmesan, C. Morecroft, M.D. & Trisurat, Y. 2022. Climate Change 2022: Impacts, Adaptation and Vulnerability. [Research Report] GIEC. 2022. ffhal-03774939f.

5. Mascia, M.B. & Pailler, S. (2011). Protected area downgrading, downsizing and degazettement (PADDD) and its conservation implications. Conservation Letters 4 (1): 9-20.

6. Qin, S., Golden Kroner, R.E., Cook, C., Tesfaw, A.T., Braybrook, R., et al. (2019). Protected area downgrading, downsizing, and degazettement as a threat to iconic protected areas. Conservation Biology 33 (6): 1275-1285.

7. Burns, F., Mordue, S., al Fulaij, N., Boersch-Supan, P.H., Boswell, J., et al. (2023). State of Nature 2023. The State of Nature partnership, Available at: www.stateofnature.org.uk.

8. Crofts, R., Dudley, N., Mahon, C., Partington, R., Phillips, A., et al. (2014). Putting Nature on the Map: A Report and Recommendations on the Use of the IUCN System of Protected Area Categorisation in the UK. IUCN National Committee UK.

9. Golden Kroner, R.E., Qin, S., Cook, C.N., Krithivasan, R., Pack, S.M., et al. (2019). The uncertain future of protected lands and waters. Science 364: 881–886.

10. Cotton, M.D. (2017). Fair fracking? Ethics and environmental justice in United Kingdom shale gas policy and planning. Local Environment 22 (2): 185-202.

11. Laville, S. & Hayhurst, R. (2022). Fracking could affect many protected areas across England as ban is listed. The Guardian 22 September 2022.

12. The Wildlife Trusts. (2019). What’s the Damage? Why HS2 will cost nature too much. Newark, Nottinghamshire.

13. The Wildlife Trusts. (2023). HS2 Double Jeopardy: How the UK’s largest infrastructure project undervalued nature and overvalued its compensation measures. Newark, Nottinghamshire.

14. JNCC. (2018). 201826 UK SSSIs damaged or destroyed due to successful planning applications between 1 January 2012 and 31 December 2017, JNCC, Peterborough.

15. DEFRA. 2012. Biodiversity Offsetting Pilots: Guidance for Developers. London.

16. Maron, M., Gordon, A., Mackey, B.G., Possingham, H.P. & Watson, J.E.M. (2015). Interactions between biodiversity offsets and protected area commitments: avoiding perverse outcomes. Conservation Letters 9 (5): 384-389.

Nigel Dudley is a Director at Equilibrium Research.  nigel@equilibriumresearch.com

Cite:

Dudley, Nigel “ECOS 45 (1) – Protected Area Downgrading, Downsizing and Degazettement (PADDD) in the UK” ECOS vol. 45 (1) ECOS 2024, British Association of Nature Conservationists, www.ecos.org.uk/ecos-45-1-protected-area-downgrading-downsizing-and-degazettement-paddd-in-the-uk/.

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