Here’s a statistic worth dwelling on: at least 80,000 lives a year have been saved because of the higher air quality standards imposed by the EU, often in the teeth of strong opposition from individual Member States.

In my personal view, it’s that sort of insight that makes the vast majority of environmentalists broadly supportive of staying in Europe (in fact, I have yet to hear a convincing case for Brexit from any serious environmentalist, including Jenny Jones, the Green Party’s spokesperson in the Lords), and broadly supportive of lending their weight to the pro-European campaign.

But this perfectly logical positioning seems to have become a lightning rod for the Brexit mob. A highly suspicious bunch of right-wing journalists, deep Eurosceptics, and so-called ‘charity transparency campaigners’ have decreed that environmental charities should play no part in the Referendum campaign, and should remain silent on the matter until the rest of the British public have had their say.

As I explained in my last personal blog on this topic, most of this is completely consistent with the kind of repressive, anti-democratic authoritarianism that has been gaining traction over the last six years within the Government and the media establishment. But now there’s a new element in this particular mix – namely, a newly assertive and increasingly politicised Charity Commission.

The Charity Commissioners recently issued new guidance specific to the EU Referendum campaign, dictating that charities should only enter the debate ‘in exceptional circumstances’. Both the wording and the aggressively hawkish tone of the guidance have been laid firmly at the door of the Commissioners’ Chair, William Shawcrossarch-Eurosceptic and unapologetic Murdoch supporter.

The guidance itself, leaked to the Telegraph with the clear connivance of someone very senior in the Charity Commission, has caused some consternation. Understandably. A number of very experienced charity lawyers believe that it’s been deliberately drafted that way to scare off certain environmental charities, and is actually much more hawkish than the underlying law. The CEO of the Association of Chief Executives of Voluntary Organisations (ACEVO) has described it as “an alarming piece of guidance that needs urgent clarification”.

Friends of the Earth was the first organisation to provide a robust rebuttal of this attempt to gag charities during the Referendum campaign: “Charities have an historic and vital role in mobilising public pressure for a better society and a safer planet.” Pointing out that the Prime Minister himself has been keen to see ‘businesses, NGOs and other organisations’ getting involved in the debate, FoE Chief Executive Craig Bennett went so far as to say that FoE Trust “would be failing in the delivery of our charitable objectives” if they held back from involvement in the campaign.

FoE’s resurgent vigour is providing a massive boost to the rest of the environment movement – as did a robust article in the Guardian from John Sauven, Executive Director of Greenpeace. By contrast, the Campaign for the Protection of Rural England (CPRE), with that rather sad little Englandism that has never been far from its often confused persona, took prompt and effective refuge in a ‘we couldn’t possibly take sides’ position. Even on such an important issue, it would apparently be invidious to present their members as being on one side of the debate or the other.

That, of course, is not the point. An organisation is an entirely different entity from its members, and it remains the responsibility of any organisation to develop a collective view of what is undoubtedly the single most important decision regarding the future prospects of the UK – including, in this case, rural England.

It’s probably true that a given percentage of CPRE’s members would inevitably end up disagreeing with any collective organisational view. Some might disagree so vehemently as to persuade them to cancel their subscription. But CPRE is no different in that regard from, say, the Conservative Party, which, as a political party, is campaigning actively for the UK to stay in the EU, much to the consternation of many individual members. Some of whom may indeed resign.

I recently flagged up the excellent report from the Institute for European Environmental Policy (IEEP), ‘The Potential Policy and Environmental Consequences for the UK of a Departure from the European Union’, and I can’t help but ask whether the collective leadership of CPRE has spent any time at all weighing up this report’s pretty definitive conclusions. Above all, it calmly spells out why it is that a Brexit would be not just a leap in the dark, from an environmental perspective, but a leap in the dark to which not one single leading Brexit advocate has given even a nano-second’s consideration. The truth is that those advocates care so little about environmental issues that they have no interest in making an environmental case for ‘better out’ than ‘in’.

The three organisations that commissioned that report were The Wildlife Trusts, WWF and RSPB. So you might imagine that they too would be out there lending their not inconsiderable weight to support Friends of the Earth. Unfortunately, it’s not quite as simple as that.

The Wildlife Trusts comes out by far the best of them. Despite being no less domestically-focussed than CPRE, with much the same sort of branch structure, and lots of members who will indeed have widely diverging views about the Referendum, its statement is carefully worded (understandably in the circumstances) but very clear in its overall positioning:

“Wildlife and habitat will be better off if they continue to benefit from EU legislation and a cross-European framework for nature conservation. We have formed this view because of the positive impact they currently bring to the UK’s wildlife, and the uncertainty about the alternative. We know where wildlife stands within the UK as a member of the European Union, but there is no certainty about its future under Brexit.”

I wish I could point to the same kind of clarity within WWF’s current positioning. I’m a proud Ambassador of WWF and a former Trustee of many years, so it matters to me that they get things like this right. But the statement from Ben Stafford, Head of Public Affairs, tells you all you need to know about the current impact of the Shawcross doctrine. Whilst providing a lukewarm endorsement of the EU’s past record (“Research commissioned by WWF and others suggests that, on balance, Britain’s membership of the EU has delivered benefits for our environment that would be hard to replicate in the event of the UK leaving”), he goes on to say:

“We should be urging both the IN and OUT campaigns to set out how they would ensure continuing strong protection for the UK’s environment. Whatever decision is made, it’s vital it doesn’t come at the expense of thriving wildlife, clean air and water, strong action on climate change, and growing green businesses.”

It’s only fair to point out that WWF decided that this would be its position many months ago, but it is still so weaselly-worded as to be positively embarrassing. We already know, as clearly as it’s possible to know anything, that a Brexit would come very much at the expense of “thriving wildlife, clean air and water, strong action on climate change, and growing green businesses.” I’m just a little bit surprised to hear that WWF doesn’t understand that.

But the position of the Royal Society for the Protection of Birds (RSPB) is even more craven. And it’s also completely contradictory. This was the first point they wanted to communicate: “Comprehensive international agreements for nature conservation and the environment are essential.” And in correspondence with my office, here’s the second, relating to their actual position on the Referendum debate: “We shall remain neutral due to restraints by the Charity Commission – charities are not allowed to be politically affiliated.”

That is actually inaccurate, if not deliberately untrue. The Charity Commission does not have a blanket ban on political actions by charities, but it does of course have a ban on any political involvement that seems to speak to a preference for a particular party. Nothing could be further from the case with the EU Referendum campaign.

If the RSPB actually believed that “we must act internationally” on all critical environmental matters, and if it has actually read the IEEP Report that it commissioned, they would know – AS A MATTER OF IRREFUTABLE FACT – that a Brexit would lead either to the UK being no longer bound by almost all the EU’s most critical international conservation measures, or to those measures being significantly undermined by virtue of the UK no longer having any say in their implementation or further development.

‘Neutrality’ seems like a pretty dumb place to have ended up given that IRREFUTABLE FACT.
So what’s it all about then? Sadly, the only possible conclusion is that both the RSPB has indeed been profoundly influenced (by which I mean cowed) by the bullying, authoritarian tactics of that bunch of right-wingers I referred to at the start, in this case, aided and abetted by the Charity Commission.

That’s the thing about authoritarianism. It’s the fear of what might happen as much as the evidence of what actually has happened that influences the decisions people take. There was a very interesting article in a recent issue of New Scientist (27th February) looking at the impact of barking dogs on populations of raccoons in British Columbia:

“Predators don’t control populations of their prey just by killing them. They also paint what is termed ‘a landscape of fear’, inhibiting prey from feeding and turning parts of their habitat into no-go zones. It appears that this has far-reaching effects throughout the food web.”

Simple message for us: unless those right-wing barking dogs are confronted by NGO raccoons sticking together, parts of our habitat will be turned into “no-go zones”. And environmental NGOs need to do this now, responsibly, and in a way that is completely compatible with any organisation’s core purposes, particularly their charitable core purposes. Otherwise, this war of attrition will just go on getting worse and worse.

POSTSCRIPT: Just to be crystal clear about this particular blog: These are very much my own opinions, and not those of Forum for the Future or any other organisation that I’m associated with. But for a succinct statement of Forum for the Future’s position on the EU Referendum, James Goodman, Forum’s Director of Futures, has admirably captured the Forum’s internal view: “Our sustainable future will be based on people choosing to work together to common goals, beyond the boundaries of sector, age group or nation, recognising our fundamental interdependence. A Brexit would be a massive lurch away from ‘our common future’”.