How feasible is the use of Natural Capital for local priority setting within Dartmoor National Park?
One of the four research strands which makes up the Dartmoor ELM Test and Trial is to "explore the role that National Park Authorities could play in shaping, facilitating and delivering ELMs".
As part of this research theme one of the project's commitments was to produce a working paper on the feasibility of using a natural capital approach for local priority setting and landscape-scale planning.
If you've not come across the term natural capital before then essentially it's about recognising the worth of the assets nature provides us with, like clean air, birds that sing, fish that swim etc., and finding ways of attributing a financial value to them. The intention is to prevent us from taking these assets for granted in our decision making and ensure the good management of them is appropriately economically rewarded.
The concept of natural capital is the economic framework on which the new ELMs scheme is built, the idea of only funding farmers for managing "public goods" is drawn directly from the natural capital approach. If you'd like to understand more about natural capital in order to better understand ELM then, as the author of the paper which follows, I feel very happy saying don't bother reading it. Do what I did and listen to Dieter Helm explain how it works instead via the Helm Talks on his website: www.dieterhelm.co.uk/helm-talks/natural-capital/
However, if you'd like to consider natural capital very specifically as a tool for Dartmoor National Park authority and how it may or may not enhance the delivery of such functions as the Dartmoor National Park Management Plan then by all means read on. However, it is worth noting that the work on natural capital is progressing at such a pace that reports such as this one can become dated quite quickly.
What is the feasibility of using a natural capital framework approach for local priority setting and landscape-scale planning: how could we use it for our own priority setting and DNPA Management Plan?
Natural Capital refers to a framework for managing the natural world based on economics. Natural assets, things like fish, which are provided to humanity for free are quantified and have a financial value ascribed to them. This data, or asset register, can then inform their management at a global, national or local scale. Essentially rather than have an economy which derives value from the unseen exploitation of natural resources this framework brings the value of natural assets into the light and onto the balance sheet. Once “on the books” natural capital has the potential to lead to better, more informed, management of natural assets because it identifies when stocks start to run too low to remain sustainable and the economic and social implications of that or it can inform how to most cost effectively increase natural assets. In particular a natural capital approach can help us value and support investment in public goods, natural assets which have a social and economic value but for which there may be little to no financial market because they are or should be widely accessible to as many people as possible such as clean air, for example.
The concept of natural capital has become thoroughly embedded in government policy through the Natural Capital Committee, inclusion in the 25 Year Environment Plan, Glover review and now the development of the new Environmental Land Management scheme.
There are two significant challenges to using a natural capital framework on Dartmoor.
1. The first is that three separate reports have concluded that data presents a significant challenge. There is a lot of data available but it’s not centrally or coherently held but spread across origanisations and individuals. Furthermore, even if that data were to be brought together into one asset register it’s likely there would be significant data gaps as lack of resource for monitoring and the inability to access all land across Dartmoor presents an insurmountable obstacle to compiling a fully comprehensive data set for the national park.
2. The methodology for using natural capital is still evolving and is still lacking the ability to consistently and reliably value some assets at a local scale. According a SWEEP report generated for Exmoor and Dartmoor National Parks this is particularly true for biodiversity and peat yet these are two of Dartmoor’s most significant natural capital assets.
The concluding recommendation of this report is that, given central government’s commitment to the use of natural capital, it is probably in the interests of the Dartmoor National Park Authority (DNPA) to start laying foundations for a natural capital approach, particularly addressing some of the data challenges. The SWEEP report on Dartmoor estimated the natural capital value of the park at £40 million (in 2016), excluding robust figures for peat and biodiversity. As and when better financial values become available the use of a natural capital framework should enable Dartmoor to build a strong business case for investment in the landscape in order to maintain, if not enhance, its national natural capital value.
The concept of natural capital was developed by economist E. F. Schumacher and outlined in his book Small Is Beautiful: Economics as if People Mattered, it was a concept inspired from his time as farm worker taking care of cows.
A more contemporary proponent is Prof Dieter Helm, Chair of the Natural Capital Committee.
In his online lectures outlining the theory of natural capital, how and why it should be used Helm outlines the key tenets of the approach.
Nature provides us with a number of assets for free, that have a value, trees, soil, water, birds etc. are inherently an asset. They are an asset even when not impacted by human endeavor e.g. a tree is of value, not just timber, and they are an asset to be valued separately from any utility, service or benefit they may provide for society e.g. the tree has inherent value, the fact that trees provide oxygen is a service which has a separate, additional, value.
Some of these assets are non-renewable, such as some elements and minerals, others are renewable, fish procreate, for example. For renewable natural capital the threshold at which it becomes non-renewable should be scientifically determined and competent management should ensure that stocks of this resource do not approach their non-renewable threshold but remain safely buffered from it e.g. if you know how many fish must remain in the water you can ensure you don’t fish a particular species to extinction.
By recognising these things nature provides freely as assets we can attribute a value to them and we can start to account for them and use natural capital accounting to guide their management; to monitor their existing state; their maintenance and any asset enhancement or decline. However, this should be done not on a historic cost account basis but a current cost account basis – what is the worth of the asset now. This will help determine the value of maintaining or enhancing that asset or the impact of its loss.
There’s a social justice/moral/pragmatic imperative to sustain these assets for future generations because they provide a flow of services upon which society depends.
Helm’s three principles for operationalizing the approach are:
1 – that public money should be paid for public goods and a public good is an economic concept that is non-excludable, you can can’t stop someone having it and non-rival, someone having it doesn’t diminish someone else having it. The opposite of private goods which are excludable and rival e.g. if you buy a leg of lamb and eat it no one else can eat it. The reason public goods need support is because they’re otherwise extremely hard to find a mechanism to pay for their delivery and because they’re something you want as many people as possible to benefit from, such as clean air.
2 – the polluter should pay
3 – any development should meet the criteria of net environmental gain
Natural capital is a good mechanism for evaluating large landscapes but doesn’t necessarily translate well to smaller projects e.g. it works well for managing an ecosystem but not necessarily evaluating a specific project relating to a single species in one location. It’s a concept which works best to a set of broad objectives.
Part of the value of natural capital is determined by public perception, people’s ability to access and benefit from it. However public opinion isn’t necessarily a good tool for determining this value because, as a society, we are all lacking in detailed knowledge about natural capital, for example a full understanding of ecosystems, and this can lead to poor decision making. Furthermore, if you’re never seen or experienced interacting with a natural capital asset, a barn owl for example, how can you determined the value of that asset, if you’ve let to live through the impacts of climate change in 2050 you may not be motivated to make changes to mitigate against it in 2020 etc.
Natural Capital and Government Policy
The concept and the principles of natural capital have percolated through government thinking and policy and have significantly shaped recent government objectives around managing the environment and farming, including the 25 Year Environment Plan, which expresses a desire for the UK to lead the world in using natural capital as a tool for decision making.
Using the Natural Capital Committee’s (NCC) natural capital framework The 25 Year Environment Plan sets six goals for environmental improvement.
1. Clean air
2. Clean and plentiful water
3. Thriving plants and wildlife
4. Reducing the risks of harm from environmental hazards
5. Using resources from nature more sustainably and efficiently
6. Enhancing beauty, heritage and engagement with the natural environment
At a national level these objectives have gone on to lay the foundation for the development of the new Environmental Land Management scheme (ELMs) and become the six public goods Defra envision ELMs delivering, with only one alteration from “Using resources from nature more sustainably and efficiently” to “Mitigation of and adaptation to climate change”. In the most recent Defra update ‘Environmental Land Management: Policy discussion document’ actions delivering an improvement or benefit to any one of these six categories were given top priority when it comes to the principles determining what ELMs will pay for.
That natural capital should “be regularly and robustly assessed, informing priorities for action” is also a proposal of the government’s Landscape Review of 2019, otherwise known as the Glover Review of England’s protected landscapes. The concept is even included in the review’s proposed rewording of the purpose of National Parks and AONBs, to “Recover, conserve and enhance natural beauty, biodiversity and natural capital, and cultural heritage.”
At a local level the current draft Dartmoor National Park Management Plan makes references to both the 25 Year Environment Plan and the Glover Review and expresses an intent to take forward these policies “in a way that reflects local circumstances”.
Through this process natural capital moves from economic theory to a tool which, particularly if you are in receipt of government funding for land management or looking to receive government funding for land management, needs to have a framework and understanding for its use in more local and specific contexts.
How Feasible is a Natural Capital approach for Dartmoor National Park? Natural Capital and the Management Plan
Government provides a range of advice on use of the Natural Capital approach including a workbook from the Natural Capital Committee and, as of March 2020, “Enabling a Natural Capital Approach: Guidance” from Defra.
In essence the Natural Capital workbook outlines a process not dissimilar from most project management strategies:
If we compare this to Dartmoor National Park’s existing management process then one can see that the vision is clearly articulated in both the organisation’s statutory purpose but also in the Dartmoor National Park Management Plan. Whilst the Management Plan is not specifically intended as a natural capital approach the new draft has brought various community stakeholders together and used different engagement tools to discuss natural capital assets, services and benefits and create a broad set of desirable outcomes.
Consequently natural capital assets are referenced in the current draft of the Management Plan, examples include blanket bogs, peat, semi-natural woodland, wetlands and rare species but the overwhelming focus across all seven themes is not on the assets but the services and social benefits natural capital assets provide, alongside social/cultural capital and services as well as economic priorities.
Using a specific natural capital approach the next step would be to develop a detailed baseline of information covering the state and condition of existing natural capital assets, their services and benefits as well as identifying any risks and any pieces of work impacting natural capital which are already in progress. It should be noted that assessments of the assets and assessment of the services and beneficiaries may cover differing geographical areas, a rare species for example may be found in one location but its rare quality may mean its services and benefits cover a much wider area. This approach is not inherently outside of the remit of the management plan, the public opinion survey, for example, saw international participants.
The existing draft Management Plan for the national park does not go into great detail on the park’s current natural capital stock or its condition, although this is often implied by the need to "restore" peat land, for example. It does articulate some data gathering objectives, such as:
- Increase understanding of carbon storage potential.
- Improve understanding of soil health.
- Review all priority habitats.
- Review all priority species to assess their sustainability in light of climate change.
- Develop the Dartmoor Vision in order to provide a framework for the identification and agreement of local priorities and spatial targeting.
The Management Plan also identifies some of the risks to natural capital, such as climate change and increased visitor pressure. Furthermore, as it’s currently only a draft, some of the questions relating to the consultation on the draft raise the issue of whether or not more data, or more data specific commitments would be of value.
In the previous version of the Management Plan (2014-2019), whilst there was more data provided in the plan itself (you would be better able to monitor success against the wording of the last plan), much of the detail was available in the supporting documents. Previously this was the Landscape Character Assessment (2017), State of Dartmoor’s Key Wildlife (2011), Biodiversity 2020, National Character Area profiles (2014) and Living Dartmoor (2013).
For this Management Plan Draft (2020-2025), from a natural capital perspective the most relevant supporting documents would appear, currently, to be the Sustainability Appraisal, Habitats Regulations Assessment and Evidence review paper: Natural Environment.
All these documents do go into marginally more detail, towards what would be required for a natural capital appraisal.
The Sustainability Assessment identifies the number of European designated Special Ares of Conservation, SSSIs, County Wildlife Sites, Strategic Nature Areas and Key Wildlife Areas, although it also highlights that ‘it cannot be assumed that these comprise all the significant biodiversity on Dartmoor’.
Some data is also provided on critical drainage areas and their priority.
The Habitats Regulations Assessment focuses on habitats and species of European nature conservation importance (so far from all relevant natural capital) as covered by the Habitats Directive. So this data crosses over with the Sustainability Assessment covering Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) but also covers Ramsar sites. Lists and sizes of significant sites are provide for both within and closely connected to the park.
More specific information is provided on some species, mostly the Greater Horseshoe Bat, including an approximate adult bat population figure, references are also made to three other species in particular but no data is provided.
The evidence review prepared by the Devon Biodiversity Record Centre provides some indicative data, in line with what might be expected from a natural capital appraisal.
It contains data indicating what percentage of the nation’s internationally important vegetation communities are found on Dartmoor, how much land is covered by SSSI designation and what percentage of that is in favourable or unfavourable recovering status and even the time frame for that status. Demonstrating how that data can be usefully mapped:
The condition of SSSIs and CWSs in Dartmoor National Park based on status dates of 2007-2017 (SSSIs) and 1990-2017 (CWSs)
However, what the review mostly emphasises is how management of the national park’s natural environment is made challenging by the lack of consistent, quality data:
“Data for the National Park is held piecemeal in varying formats by a number of stakeholder organisations, having been derived from sources including Natural England’s Priority Habitat Inventory, DBRC and DNPA surveys, and NBN data from SSSI survey and condition monitoring. Our knowledge changes as sites are resurveyed, and the sites themselves are constantly being expanded, reduced, transformed into different habitats (by design or by natural succession), or lost entirely due to changed management or development. Habitats within the large SSSI commons should in theory be easier to keep track of as these sites benefit from regular NVC vegetation mapping undertaken by Natural England, but even here there are difficulties – firstly with accessing the data collected, and then with the lack of resource available to carry out detailed analysis of it.”
Highlighting that this impacts not just on the ability to give an accurate current assessment of the natural environment but also makes it less likely data can be used to understand the impact of environmental challenges. Particularly as a loss of some of these key species may not reflect management on the ground but result from factors such as climate change.
The review also questions whether the historic State of the Park approach is the right one, whether the focus on such a small number of species and key areas negates, rather than enhances, the understanding of biodiversity.
How Feasible is a Natural Capital approach for Dartmoor National Park? A Natural Capital asset register
The problem lack of data presents is that the Management Plan in its current format cannot play a meaningful role in either providing assessment of the Park’s natural capital or robust monitoring of its condition when so little data is incorporated.
As the Sustainability Assessment highlights in its section on ‘Key Sustainability problems and opportunities identified’ this is not a complete picture of the National Park’s natural capital assets. It means that assets which may currently be undesignated but have the potential for designation in future or which are just as important from a local perspective go unrecorded. Many assets may go entirely without recognition for lack of identification or mapping. Lack of data also prevents the kind of ongoing monitoring suggested by the Sustainability Assessment which relies on the ability to have clear data based targets, for example the percentage of geological SSSIs in favourable or unfavorable condition.
A wide variety of natural capital data sets are available, listed in the NCC’s work book and the national park and other local bodies have additional information. The inclusion of more data in either the management plan or supporting documentation, as suggested by the DBRC review, would make the aspirations expressed in the plan more robust and meaningful. As highlighted in the SWEEP report on natural capital produced for DNPA, consistent natural capital monitoring over time would also help identify the impacts of some of the identified challenges, such as climate change and recreation, but also the impacts of decision making, where one objective is prioritised over another, for example archaeology over nature conservation. More detailed accounting would also enable the identification of assets most at risk, pushed beyond the point of sustainability.
The natural capital SWEEP report recommended that, “To overcome these limitations in the level of detail, classification accuracy and repeatability, the National Parks would need fine-scale, park-wide data on land cover, split into habitat categories of management relevance. These data should also be collected consistently and repeatedly over time (e.g. annually) in order to allow for accounting and monitoring for changes in extents, flows and values over multiple years”.
In a presentation to the Exmoor Society in April 2017, Dieter Helm outlined his thinking on the natural capital approach for national parks and essentially a very simple four point plan:
1. Asset register
2. Assets and risk
3. Capital Maintenance
Creating an asset register of the national park’s natural capital would certainly seem a good first step, the challenge is then, what data to include.
In Defra’s “Enabling a Natural Capital Approach: Guidance” the suggestion of using the UK National Ecosystem Assessment “Broad habitat types” but these are clearly far too broad to be of much use in dealing with the variety of habitats found within the national park and the objectives of the management plan. The guidance reflects on that highlighting that the Natural Capital Committee’s asset typology might be more useful at recognising ecological complexity.
Whilst these thematic groupings are probably more helpful in defining appropriate natural capital assessments actually, to provide robust data for management plan reporting, a natural capital asset register for Dartmoor would almost certainly need to go into finer detail within each category. The SWEEP natural capital report endorsed such an approach, using the RSPB as a case study, “We would recommend that such a list of species includes wildlife from a range of species groups and habitat types, and that species of both local and national conservation importance are considered.”
There are also a number of natural capital approaches developing as part of the ELMs tests and trials, predominantly focusing in on habitat mapping (because this is a tangible asset, there are existing assessments for condition which can then be used to identify opportunities for improvement, it’s an asset which doesn’t usually fluctuate significantly over time in contrast to butterfly populations for example,) which can be used as a proxy for wider biodiversity assessment.
The Farming Wildlife and Advisory Group have opted to use UK Habitat classifications for their mapping tool. The tool effectively demonstrates how you can take a relatively small number of original classifications of habitat type and then work down through sub classifications to create a more detailed picture of your assets.
It’s a good template to follow - create a taxonomical framework for each natural capital theme and then you can begin with relatively simple asset identification exercise but continue to add more in-depth classifications when time, resources and, sometimes, science permits.
Once such data for the full range of the national park’s natural capital was in place it would strengthen the national park’s ability to report against its management aspirations. It would then enable setting of more robust management targets and evaluating whether a net gain has been achieved because year on year data would be available. Such data would also enable monitoring of the impact of risks both current and future, such as the impact of climate change.
Ideally each classification also has a corresponding assessment method in order to identify not just what the asset is but its condition. Not least, as highlighted in the SWEEP report, as some natural capital services can move from positive to negative if not maintained, for Dartmoor peat condition would be key, for example. So a condition assessment is necessary to understand the potential service flow.
A risk register could be created to parallel those which already exist for buildings and monuments so that different elements of the national park’s work could report consistently and the current condition be easily comprehended.
Natural Capital Accounting
The next step in the process, according to the NCC’s work book, would be to start to use the natural capital accounting approach of attributing values to all the assets to help inform decision making.
It would seem futile to expand on that in this assessment given that multiple reports identify that the natural capital approach hasn’t yet developed to a point where this can be usefully applied to either the scale of the national park or its key priorities. The SWEEP report highlighted that existing methodologies struggled to value both biodiversity and peat which are two of the national park’s most significant assets.
In its summation the SWEEP report states that, “Accounts, and the perceptions of organisations regarding what Natural Capital Accounts can be used for. While it was felt that the underlying idea behind natural capital accounting could prove useful, there has been a consensus that Natural Capital Accounting is still in its early days, and that the methodology and framework need to be improved substantially before the approach can become useful to inform management decision-making for environmentally-facing organisations such as National Parks.
One of the major concerns raised by stakeholders was regarding the reliability of the Natural Capital Accounting approach and the resulting total value estimates. As shown in section 4.2. [of the report], account results are highly sensitive to the underpinning data sources used to measure natural assets, flows of ecosystem goods and services and values. Such variability makes current standard practice for Natural Capital Accounting at an organizational scale an unreliable instrument for decision-making.”
The SWEEP report was finalised in December 2019 and January to March 2020 saw a range of new government advice produced on the use of natural capital accounts. It may be worth a short review of the SWEEP findings, given one of its criticism was a lack of standardised accounting methodologies, as this may be addressed by some of the new guidance. However, that still doesn’t mean that the accounting approach has reached a stage where it may be a valuable decision making tool to the national park. Even in the latest guidance from March 2020 there’s still an acknowledgement that the UK natural capital accounts ability to appraise the value of biodiversity remains crude and “may not capture the full welfare benefit of a service” and that the accounts status remains “experimental”. The report endorses Professor Helm’s view that the limitations of our knowledge remains a significant barrier, “economic valuation assumes we know what is to be valued. However in the case of complex ecosystems, ecological processes and their interdependencies are not fully understood, and outcomes from loss or enhancement are uncertain. In these cases, valuation of individual ecosystem services will be inadequate. Reasoned or evidence-based arguments for action or inaction may be more appropriate.”
In reflecting on whether the current inadequacies of the financial methodologies reduce the feasibility of a natural capital approach one key observation is that the national park’s objective is not a financial one. Its main purpose is essentially to conserve and enhance the natural capital of Dartmoor regardless of that capital’s value. So all the strengths of the natural capital approach, the attention to detail and reliance on robust, science and user led data for accurate reporting are valuable tools, worth utilising, regardless of whether the economic elements are fully developed, They enable the management plan to move from broad aspiration to a system which provides tangible evidence for proof of delivery.
Furthermore, as the economic models become more standardised, assuming the initial economic findings aren’t disproved completely, it could clearly be in the economic interests of the national park land management community to adopt the natural capital approach. The Farming and Forestry Review paper which accompanied the Dartmoor Debates series, informing the current draft management plan, highlighted that in 2016 environmental stewardship payments worth £4.7 million were received by farmers within the national park. The SWEEP report into the value of the national park’s natural capital for 2015 places a value of £30 million on the public benefits provide by the natural capital, with an additional £10 million in private benefits, despite that fact that a large proportion of the natural capital value was either fully or practically overlooked by the standard practice accounting utilised. Furthermore the value of many ecosystem services is likely to increase over time due to scarcity, rising demand and climate change.
Referring back to the previously mentioned presentation Prof. Helm gave to the Exmoor Society when one has a natural capital asset register and asset risk register, providing data enough to value the assets within the national park, it’s easier to identify and articulate the true value of the capital maintenance cost and enhancement costs of those assets. If future government subsidy is likely to be linked to a natural capital framework, which is already indicated by thematic references in existing policy documents, it’s clearly in the financial interests of land owners and managers within the national park to adopt the natural capital approach to build a more explicit business case for maintenance and enhancement costs.
Summary on the best use of Natural Capital or “You can’t manage what you don’t measure”
In its own reflections on the relevance and use of the Natural Capital approach to National Parks the Glover review surmised that, “If we are to restore nature, and make it resilient – and grasp the economic opportunities which come from properly accounting for and protecting nature – we must start by understanding what we have, and have a regular way of checking its health, so we can focus”.
Despite the fact it was not intended as a natural capital document the evidence review paper on the Natural Environment, produced for the management plan, already addresses this need. The review highlights what makes the feasibility for delivering this challenging:
The National Park isn’t primarily viewed as a body with responsibility for data collection. Whilst it has data on the majority of assets it doesn’t necessarily have the resources to perform large data gathering exercises where further information is required.
The National Park has no statutory authority to access and monitor natural capital on private property which means land owners can withhold permission for monitoring of, potentially quite significant, assets within the national park.
Dartmoor’s natural capital data is held by a number of different organisations so monitoring methods and mechanisms are not necessarily consistent nor can every organisation, necessarily, be compelled or financially incentivised to share their data. In recent years this problem has been compounded as members of the public with an active interest in a particular variety of natural capital, who often provide data to monitoring organisations, may instead be utilising any number of different recording apps available which don’t necessarily make that data readily available.
That existing data reflects only what and where people are motivated to record.
One might also add that existing scoring of condition only reflects current knowledge and thinking. On key areas for natural capital such as soil, for example, an upsurge of interest in soil health has lead in recent years to much better tools for measuring soil health. There is also an increasing desire to reflect the more dynamic, ‘working with natural processes’ approach, which may need new targets and monitoring techniques to allow and account for dynamic interactions.
The review also makes some really good recommendations on how to overcome some of these challenges:
Continue to support research and development of new technologies which enable better or more efficient natural capital assessment.
“The Management Plan Review should address the importance of keeping Dartmoor’s common species common by selecting a representative suite of organisms - indicative of broader habitat health - for regular long term monitoring. Ideally these should be species that could be monitored alongside existing priority species, adding valuable information without a significant increase in survey efficiency.”
Work with other bodies to monitor and share data about flagship species, and other natural capital assets, across Devon. “Bringing all of this information together to support the management and enhancement of Dartmoor’s Key Wildlife Areas might have considerable merit. Furthermore it would enable DNPA to engage more directly with the large number of local volunteers who help to deliver these initiatives, many of whom will have little knowledge of the Authority’s involvement with the natural environment.”
Support and encourage citizen science projects that enable extensive data collection.
These recommendations have already been made as a means by which to enhance the delivery of the management plan but if a drive to enhance data management within the Dartmoor National Park Authority is taken up then it will also create a strong foundation for a natural capital accounting approach as and when that mechanism is improved.
In the meantime if all of the national park’s landscape assets are clearly categorised in registers then a view across all risk registers could be used to prioritise areas of work, map out spatial priorities and opportunities and identify conflicts between priorities.
Alternatively, it could be approached the other way, working back from the services prioritised by the management plan to identify which natural capital assets need additional resources or management, in line with the table below from the Natural Capital Committee.
As and when the financial evaluations have reached a stage where they can provide a robust and consistent value for Dartmoor’s assets this information can then be easily added to the existing asset register. The values can then be used to inform decision making either by using financial value as a proxy to determine net gain or to inform a cost benefit analysis which would indicate where investment in natural capital assets could have most impact.
Lastly, rather than create a new approach to natural capital management it may be better to follow the recommendation of the Glover review that a greater level of consistency in natural capital monitoring is applied across all national parks and either adopt approaches already in use by other national parks, like Exmoor, or come together with other national parks to agree a shared framework and reporting approach going forward.