Responses/Comments Articles

Re-wetting Dartmoor's Mires - Update

Posted in Responses/Comments on Thursday 5th August 2010 at 8:37pm

Brief reports expressing our concerns about works to ‘rewet’ Dartmoor’s blanket peat have appeared in Newsletter 34, pp5–7 and 35, p13. A new phase of activity is about to be launched.

A 5½-page report went to Dartmoor National Park Authority on 8 January 2010, revealing that between £1 million and £1.3 million is to be allocated to Dartmoor National Park by South West Water towards a 5-year project commencing on 1 April 2010, now titled ‘Mires on the Moors Project’. The project will ‘develop plans for and implement restoration of around 110 hectares of blanket bog within the Forest of Dartmoor, in consultation with stakeholders.’

The report states baldly that there are areas ‘where erosion is seriously reducing the quality of Dartmoor’s blanket bogs’ and that ‘most of Dartmoor’s blanket bogs have been damaged or threatened by encroaching erosion’. We have requested data and evidence to support these statements and so far have been sent some rather unconvincing ground images. We are seeking further evidence to support these claims.

Dr Tom Greeves wrote to Dr Kevin Bishop, Chief Executive of DNPA, in January 2010 requesting formally that The Dartmoor Society should have representation on the proposed Project Board, especially as we are the only body to have organised highly relevant public debates on Dartmoor’s Vegetation (2006) and Dartmoor’s Water Resources (2008), as well as hosting a Research Lecture on ‘Climatic & Environmental Change on Dartmoor’ by Dr Ralph Fyfe in 2007 – all of which have been published in our Newsletter and/or website. He replied saying that he would be ‘keen to ensure that we find a mechanism whereby the experience, enthusiasm and contacts of Dartmoor Society members can be used to support and guide the Dartmoor Mires Project along with the views of other partners’, and said that he would discuss our formal request with funding partners in mid-February.

Of significant concern is the fact that existing works on Amicombe Hill and Blackabrook Down, and proposed works on Winney’s Down, are all ‘Works on Common Land’ and fall under the remit of the Commons Act 2006. Large quantities of timber are involved in making the dams (some 200 on Blackabrook Down alone), carbon-emitting vehicles are used, and the turf itself is partly broken to consolidate dams. Consent from the Secretary of State (via the Planning Inspectorate) is required (Commons Act 2006 Section 38) for ‘restricted works’ which include ‘any that prevent or impede access to or over the land. They include fencing, buildings, structures, ditches, trenches, embankments and other works, where the effect of those works is to prevent or impede access’.

Several graziers are very concerned about the impact of the dams on grazing, on the lears (traditional grazing areas to which animals are attached), and difficulties for movement of cattle and sheep through the newly wetted zones. There are also issues affecting archaeological features and general access for the public. Unlawful works under the Act include those that ‘could compromise the cultural, conservation or recreational value, or the openness of the common.’

On 2 December 2009 Professor Ian Mercer stated at a meeting of the Commoners’ Council (of which he is Chairman) that ‘the damming [on Amicombe Hill and Blackabrook Down] has not gone through the right legal processes’. Dr Tom Greeves wrote to Prof. Mercer on 9 December requesting ‘that the Commoners’ Council, as the statutory body with responsibility for management of the commons of Dartmoor, takes the lead in ensuring that formal application is made by all parties concerned to the Secretary of State for existing and any future planned works on the blanket bog of Dartmoor’.

Not surprisingly, Natural England apparently believes the works are exempt. However, this has not been put to the test and, under the Commons Act 2006, ‘Anyone undertaking exempt works must confirm that those works come within the terms of the exemption by posting a notice on site and informing the Secretary of State’. To our knowledge no such notice has been posted at Amicombe, Blackabrook or Winney’s Down. Under the Act ‘if works are carried out that go beyond the scope of an exemption, then any person may take enforcement action against them’.

We believe that application for consent for these works should be made. Under the Act, ‘Applicants must advertise their proposals and make copies of plans available for inspection locally so that the public can make representations’.

There is scope for a public local inquiry or hearing and it seems that such an inquiry would be appropriate in this case, given the scale of the works involved, uncertainties about their purpose and efficacy, and significant concerns among graziers and the general public relating to grazing, access and cultural heritage. We have no objection to the pure research elements of the project (e.g. dating of the peat) but believe the project as a whole is yet another instance of external bodies interfering on Dartmoor, driven by the availability of large sums of money.

The momentum derived from funding, the fashionable pursuit of carbon management and the ‘partnership’ label can, as appears to have happened in this case, lead to a high-handed and arrogant approach, lacking in sensitivity to the traditional users of the ground, and the land itself, which would not have been tolerated if another body had suggested such works on common land.

Professor Mercer is seeking further guidance and clarification from the Planning Inspectorate.

Meanwhile, we ask members to be alert to any advertised notices for consent, or exemption from consent, on the ground or in newspapers. We welcome any information regarding these notices or any comments from members regarding the project in general.

Tom Greeves

Response of the Dartmoor Society to "Protected Landscapes - Natural England's Draft Policy for Consultation 2009"

Posted in Responses/Comments on Wednesday 2nd June 2010 at 8:29pm

1. The Dartmoor Society (hereafter ‘The Society’) was established in 1998 and now has more than 600 members.  It is not a ‘national park’ society but is ‘an independent voice for those who find Dartmoor a source of livelihood or inspiration’. Its charitable aims are educational in the broadest sense.
2. The Society notes [final para of ‘Context’] that the European Landscape Convention definition of landscape is claimed to form the basis of the approach to management of AONBs and National Parks in England, emphasising ‘the integration of people and nature over time, and the importance of involving local communities living in or near them in their management’. While applauding the principle, the Society finds that actual management, at least in the context of Dartmoor, falls far short of this ideal.
3. Paragraph 4 under ‘Issues’ states that the ‘character of designated landscapes is generally being maintained or enhanced’, based on evidence from the mid-1990s. The Society believes this statement is now woefully out of date as the management of the moorland areas of Dartmoor have reached a critically damaging state (especially in terms of hill farming culture, the cultural heritage and access – see below). There needs to be impartial research to assess the present condition of designated landscapes in terms of human culture as well as ecological health.
4. The Society believes (re paragraph 5 under ‘Issues’) that there is a fundamental problem with the ‘natural beauty designation criterion’ of protected landscapes and that this needs radical reappraisal and probably new legislation.
5. IUCN ‘Category V Classification’ (paragraph 8 under ‘Issues’). The Society is surprised at the claim that there is ‘insufficient attention to nature conservation objectives’ in protected areas. On Dartmoor the opposite is true, with ‘nature conservation’ dominating agricultural and land management policy relating to moorland, with a consequent detrimental effect on hill farming, on cultural heritage and on access, largely through a rapid overgrowth of vegetation. If a new principle was established that nature conservation should ‘take priority over other objectives in cases of conflict’ this would exacerbate the situation on Dartmoor and would undermine and limit ‘holistic’ approaches which integrate nature and culture. The Society believes that greater emphasis needs to be placed on nature conservation, and other conservation measures, in the ‘ordinary’ landscape and unprotected areas of country, town and city, in order to prevent so-called protected landscapes becoming ‘reserves’ surrounded by increasingly degraded landscapes.
6. Policy 1 – the mention (regarding England’s ‘nationally protected landscapes’) of ‘a healthy and accessible natural environment’ without reference to any other interests (e.g. cultural environment) is flawed as it has little meaning on the ground. The statement (para 2) that ‘England’s system of landscape designations affords the highest level of statutory protection for our nationally important landscapes’ is highly debatable. What precise protection does national park or AONB status bring? – on Dartmoor and elsewhere a ‘national park’ label has done nothing to protect hill farming culture nor has it prevented the calamitous overgrowth of vegetation on much of the moorland. There needs to be a debate as to whether national park and AONB designations are really appropriate in the 21st century when there is an urgent need to treat all land with equal care in respect of our natural and cultural heritage.
7. Policy 2 – the stated aim that protected landscapes ‘should demonstrate exemplary environmental management’ is a principle the Society supports but, within Dartmoor, despite 60 years of existence as a national park, this goal seems almost as far away as it was in 1951 (when Dartmoor was designated) with the national park being openly hostile to some environmentally sustainable enterprises, and having a very poor record on conservation of historic buildings (especially those of more recent  date), having a housing policy that has allowed a great increase in dwellings, and being generally ineffective when dealing with Natural England and/or DEFRA.
8. Policy 3 – the Society welcomes the acknowledgement of ‘the legally vague concept of “natural beauty” ’ (para 3). This should be done away with altogether as almost meaningless. What is meant by ‘a more transparent and meaningful duty of care’ (para 4)? 
9. Policy 4 – the Society welcomes the statement (para 3) that ‘the family of landscape designations cannot grow indefinitely’. There are far too many overlapping and confusing designations. What is needed is overarching legislation that protects every piece of land from inappropriate development by requiring a period of pause and rigorous analysis of information about the qualities that that land contains (in terms of ecology and culture in the broadest sense). As a starting point in the planning process there should be a presumption against development until its proposed benefits can be demonstrated as overriding any ecological and cultural values the land contains.
10. Policy 5 – Heritage Coasts. The Society has no specific view on this policy.
11. Policy 6 – the Society welcomes the statement (para 2) that ‘agri-environment schemes must be clearly working’. In the case of Dartmoor’s moorland, they have been disastrous in the past 15 years or so. Natural England and DEFRA should in future play a purely advisory role, assisting the Dartmoor Commoners’ Council. The latter has a statutory brief (under the Dartmoor Commons Act 1985) to manage the moorland, which is reinforced in Dartmoor National Park Authority’s Management Plan 2007-2012 (December 2007), p.31 which states ‘Under the Dartmoor Commons Act 1985, the Dartmoor Commoners’ Council governs the exercise of common rights, animal husbandry and vegetation management on the commons’. This seems clearcut, but Natural England and DEFRA have usurped this role and have applied quite inappropriate land management and husbandry policies (re grazing and burning) with (in the words of a Dartmoor hillfarmer) ‘total ignorance and frightening arrogance which has left a deep wound on both Dartmoor and the farming community.’
12. Policy 7 – European Landscape Convention. The Society endorses the need for ‘Exemplary management, knowledge and good practice’ of all landscapes, and advocates a radical change in the whole culture of management of protected landscapes. The Society believes that the very label ‘national park’ can lead to woolly, comfortable and mediocre thinking, and that there needs to be debate about removing it, as being both unnecessary and potentially damaging for the sound management of Dartmoor and the non-designated areas surrounding it.

Tom Greeves

Comment on Local Development Framework - Development Management & Delivery - Development Plan Document 2006-2026:Parts I-III

Posted in Responses/Comments on Wednesday 2nd June 2010 at 8:27pm

In Newsletter 35, June 2009 p.14, reference was made to the comments made on the new  Development Management & Delivery Development Plan Document 2006–2026 (DMD).

The aim of the new document is to provide ‘extra detail’ and ‘more strategic guidance’ for the Core Strategy policies. Dr Tom Greeves has responded to the consultation document on behalf of The Dartmoor Society and the full response is shown below.

The present document is in three separate A4 parts, totalling 106 pages. No fewer than 69 Topics are highlighted, often with multiple questions which the consultee is invited to answer. Reference is often made to policies which are set out in detail in the DNP Local Plan First Review 1995–2011 (adopted October 2004) and summarised on pp.76–82 (Annex 1) of the Core Strategy.

Specific response to selected Topics in Part I – Development Management Policies

Topic 1 – regarding renewable energy there is an urgent need for a DNPA policy to draw up and implement a Renewable Energy Strategy for the whole of the national park. There should be a policy which encourages ‘permaculture’ developments (such as that at Steward Wood near Moretonhampstead) as a means of demonstrating alternative ways of living that have minimal impact on the environment. At this stage such developments should be given temporary permissions (with the possibility of renewal) so that their achievements can be properly monitored.

Topic 2 – a Moorland Policy is needed which is more flexible than Local Plan (LP) Policy ML1 in order to reflect the needs of genuinely sustainable moorland communities. This policy should include the possibility of small-scale stone-cutting, peat cutting and even mineral exploitation to provide specific resources for local needs.

Topic 6 – Built Environment. The Society would support a policy which identified buildings of ‘special local interest’ which might not be listed under national criteria. There is an urgent need to recognise the importance of 20th century buildings, including those built of non-‘traditional’ materials and form, which are part of the social and architectural history of Dartmoor.

Topic 8 – it would certainly be useful to have policies on carbon reduction and energy efficiency measures and satellite dishes on historic buildings, and on public art.

Topic 9 – Heritage Assets. Policies committing DNPA to provide detailed information to the parish level about the historic and cultural environment of each settlement and parish would be welcome e.g. on the parish boundary, on tithe map field names, on known archaeological features and on historic buildings. A policy is needed which recognises that new discoveries and interpretations will continually be made.

Topic 10 – Premier Archaeological Landscapes. There is no need for specific development management policies for these areas as their wellbeing depends largely on sufficient numbers of grazing animals and a regular programme of swaling. In other words, their management is inextricably linked to the wellbeing of farming communities.

Topic 11 – Pre-development archaeological evaluation.  LP Policy AH5 needs refining with the effect that ground evaluation should take place even if nothing is recorded on the Historic Environment Record – this will give the opportunity for new discoveries to be made.

Topic 13 – Peat Deposits. These in themselves will be sufficiently protected by other policies, but a policy stating the intent to carry out research on peat and human uses of it over millennia would be welcome, as our knowledge is very limited at the moment.

Topic 20 – Primary Shopping Areas in Local Centres. It would be useful to have a policy which defines these.

Topic 25 – Extensions and alterations to dwellings. The Dartmoor Society since its inception has consistently argued that constraints should be imposed on extensions and alterations which enlarge modest dwellings so that they become unaffordable, so a policy to this effect would be welcome. A policy which recognised the inherent integrity of any building as built would be useful.

Topic 26 – Replacement Dwellings. We would support a policy which tightened control over replacement dwellings which have often led to the loss of modest and historic structures (especially bungalows).

3. Specific response to Topics in Part II – Settlement & Site Specific Policies

Topic 1 – Development Boundaries. Rather than a defined development boundary it might be more useful to have, for each settlement,  a map showing where development should not take place i.e. on key open spaces, historic features etc. The fundamental principle should be one of a presumption against development, unless very cogently and rigorously argued.

Topic 4 – Open Space. Yes, it is vital that there should be a policy which defines and protects significant open spaces within settlements.

4. Other Issues

4.1. Population – many of our current environmental problems are caused by the pressure of people. With world population due to rise to around 9 billion very soon, it would be appropriate to have a policy statement about the size of a residential population within the national park and their rates of consumption of resources both local and further afield.

4.2. Housing – we remain deeply concerned as to how DNPA is going to be able to limit permissions to the guidance in the Regional Spatial Strategy of 50 new dwellings per annum within the national park 2006–2026 (i.e. a total of 1000 new dwellings over the 20-year period). On 22 May, Chris France, Director of Planning & Sustainable Development told a ‘Forum’ meeting that 247 new dwellings had already been granted permission in the two years 2006-2008, and admitted that the current rate was running at 2 ½ times the guidance rate. The public will quite rightly be sceptical of the decision-making process if the guidance figures are not adhered to.

4.3. Biodiversity – we urge caution in the tendency to emphasize the exceptional species and habitats. Many species sites and occurrences on Dartmoor are of international importance because of the loss of habitats elsewhere. Policies are needed which protect the ordinary and commonplace fauna and flora which provide the basis for a healthy ecosystem.

4.4. Sustainable communities – there is an urgent need for DNPA to quantify the loss of services and facilities within the national park over the past 50 years, and to develop policies to protect and expand what little remains.

4.5. Prudent use of resources – this is a fundamental concept, promoted by the Dartmoor Society. It is good to see mention of water (Part I p.33) but there should also be mention of, and policies relating to, timber, stone, soil and minerals.

4.6. Inset Maps for Rural Settlements (Part II p.11) – yes, maps are definitely needed for each Rural Settlement and each should have a Conservation Area or ‘special policy area’ marked. See also 3. Topic 1 above.

4.7. Lydford (Part II p.40) – the ‘late, unremarkable and modest’ buildings of Lydford actually add greatly to its character and are of historic interest in their own right.

4.8. South Zeal – Ramsley Mine should be included in any Conservation Area because of its importance to the community.

4.9. Walkhampton – no mention is made of the proposed Conservation Area which was put out for consultation in 2008.

4.7. Corrections – ‘concentric slopes’ (Part II p.20) needs rewording. The term ‘burgage plot’ is incorrectly used re Horrabridge (p.26), South Brent (p.32) and Sticklepath (p.44) as none of these settlements was ever a borough.

5. A Proposal for a Sustainable Future

The Dartmoor Society advocates that each settlement, large or small, within the national park, should have a policy document drawn up which sets out where the fundamental resources of a) energy supply, b) clean water and c) construction materials for sustaining that community will come from in the next 20 years.