APPENDIX 'B'
13
Mr D Reyes
General Division
30 December 1987
CONSERVATION IN THE DEPENDENT TERRITORIES: FRAGMENTS OF PARADISD
Thank you for the opportunity of commenting on the above, which, despite my own well-known interest in the matter, I am doing from a purely 'official' viewpoint.
Pages 131-152
GIBRALTAR
1. Vegetation, Flora, Fauna, Marine bahibats and rescurces
The sections on vegetation, flora, fauna and marine habitats and resources are factually correct, though very brief, summaries of the situation. The length of this last section unfortunately reflects the lack of specialist knowledge on the subject.
2. Conservation situation
Again this is an accurate statement, except that no mention has been mode of the equivalent UK Government agency working in Gibraltar, i.e. DOE. This ie important considering that some of the major wildlife sites in Gibraltar are on MOD land.
3. Conservation legislation
Unfortunately end alarmingly, Gibraltar in years behind in the implementation of the ERC Firds Directive and other international agreements on conservation, including the updates on the Convention on Trade in Endangered Species and the Bona, Ramsar, Barn and World Heritage Conventions. This is despite the fact that in most cases Gibraltar is included in the UK's ratification of these. There is cause for concern not only because Gibraltar is not fulfilling international obligations, but because it would not, in my opinion, be impossible for legal action to be taken against the Gibraltar and/or UK Governments if, for example, some important site were destroyed.
However, in as far as the EEC Birds Directive and the Convention on Trade in Endangered Species are concerned, legislation has been drafted by AG who has been awaiting comments from the GONHS for some time. The GONHS should be pressed on this matter.
4. Protected areas
Since the report was written, the MOD has agreed to designate Windmill Hill Flats as a conservation area. There have also been approaches from the GONHS urging certain sites in Gibraltar to be designated Sites of Special Scientific Interest. This would not be a difficult or costly step to take and would be timely following this report.