Filling In the Gaps

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By Rob Parry, Chief Executive Officer

The Initiative for Nature Conservation Cymru (INCC) was founded in 2018 as a charitable incorporated organisation. Our vision is of ‘a Wales with more wildlife in more places, created by a society that intrinsically values the natural world’.

INCC was formed in response to the growing need for a truly independent nature conservation organisation for Wales. An organisation that was able to speak out and challenge environmental decision makers to do more for wildlife.

Prior to its formation as a charity, INCC trustees consulted with a wide variety of academics, volunteers and practitioners working in the nature conservation sector. The question asked was - where are the gaps in nature conservation and how could a new organisation fill them?

With the UK being described as one of the most nature depleted countries in the world, and long-term trends showing a decline in many of our species and habitats, the identified gaps in the sector were huge and numerous. However, a strong theme emerged regarding the ‘importance of being independent from government’.

Therefore, to remain uncompromised and objective INCC does not seek or accept direct funding from Welsh Government or its statutory environmental body. Instead, INCC relies on the generosity of individual supporters, grant giving trusts and foundations. This stance, which is at the core to INCC’s existence, enables us to speak out openly to challenge environmental decision makers without fear of reprisal or loss of funding.

To help achieve our vision, we undertake a wide variety of nature conservation activities, including:

• Advocacy and campaigns
• Targeted species and habitat conservation projects
• Research, surveys and monitoring
• Practical habitat management and landowner advisory
• Community engagement and education

Advocacy and Campaigns

Soon after forming, INCC was able to instruct solicitors to investigate whether Natural Resources Wales (NRW) acted unlawfully by breaching several of its statutory duties. Specifically, by failing to object to a development proposal that would have destroyed part of a Site of Special Scientific Interest (SSSI) in Mid Wales. The SSSI in question is one of the last remaining fragments of species rich rhôs pasture in Mid Wales.

Legal counsel suggested that NRW may have breached its statutory duties under several pieces of legislation including the Wildlife and Countryside Act 1981 and the Environment (Wales) Act 2016.

As disparity grows between the urgency to halt biodiversity loss and the resources available to do so, the very least that we should expect from our statutory bodies is that they uphold their legal and statutory duties.

However, in 2021, INCC sought legal advice against NRW’s decision making once again. This time regarding an afforestation development in Carmarthenshire. The case was complex and involved the afforestation of 73ha of upland farmland and its impact on landscape, heritage, culture, community and biodiversity. When studying the Environmental Impact Assessment (EIA) screening request for the project, it felt clear to INCC that there were serious issues with the way that NRW had dealt with the case. Particularly given that the site lies immediately adjacent to a SSSI, a Special Area of Conservation (SAC) and a Special Protection Area (SPA).

After several months of evaluation, legal counsel advised INCC that there was a real risk that NRW’s decision and its consideration of the project was unlawful. Over a dozen failings by NRW were discovered when evaluating this one application alone, the greatest of which centred on the complete lack of a Habitat Regulations Assessment (HRA).

NRW disagree with INCC’s findings, but with more and more afforestation applications being made in Wales, INCC still asks the question, do we have a statutory body that is able, willing and suitably resourced to protect our environment and reverse the declines in biodiversity?

Species Conservation

A well as challenging environmental decision makers, it is also important to challenge ourselves as a nature conservation organisation as well as the wider conservation sector. Are we getting it right?

INCC have been keen to explore species specific nature conservation, and in particular the need for population restoration projects. Population reinforcements can be incredibly effective in creating and restoring habitats, saving target species, engaging with communities and supporting a wealth of other associated biodiversity. Yet, despite their potential benefits, population reinforcements are an underused ‘tool’ in the nature conservationist’s ‘toolbox’, and often much maligned “we shouldn’t interfere, we are not gardeners”.

In 2021, INCC challenged convention by taking (under license) 80 marsh fritillary caterpillars from the wild to start the first captive rearing programme for marsh fritillary in Wales. The project is designed to reinforce a marsh fritillary population in a South Wales landscape. From the original 80 caterpillars, several thousand caterpillars have been released back into the wild in and around Llantrisant Common, South Wales. In June 2022, marsh fritillary butterflies were seen laying eggs at the Common for the first time in over 20 years. The project still has a long way to go before we can call it a success, but through the project we have been able to engage with landowners, communities and partners to restore habitat in the landscape, increase monitoring and help safeguard this iconic species.

The Future

INCC is still a young organisation, and we look forward to growing and delivering even more in future. Wherever the direction takes us, our founding ethos of independence from government and being able to speak out to challenge environmental decision makers will always remain.

For further information about INCC and our work, please feel free to contact Rob Parry, rob.parry@incc.wales

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