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Responses/Comments
Photo: Mike Rego
Posted in Responses/Comments on Wednesday 11th May 2022 at 8:34pm
We have commented on a number of plans and policies over recent years, with specific regard to local issues thrown up by climate change. We are conscious, however, that these don’t necessarily reflect the views of all our members, or capture other innovative and constructive ideas that might be relevant to Dartmoor.
We have gathered together in a single document a number of previous comments, along with some fresh ideas, as the basis for discussion.
We are currently working on a new website for the Dartmoor Society and we are looking at ways that members can contribute thoughts and comments to this document and future policy statements.
Members comments will also be taken into account in any future public consultation exercises.
Our Position on Climate Change in the Dartmoor Context
In our view, Dartmoor should not simply be seen as a carbon store in the context of tackling climate change and we see inherent dangers in the commodifying of carbon offsetting and its commercial exploitation, in addition to the potential negative impacts of projects driven by public funding schemes rather than clearly identified needs and justifications.
Dartmoor is different to the rest of Devon and the Southwest in many respects and should be treated as such so any general Government policies should be tailored to the specific circumstances of Dartmoor. This is particularly the case when it comes to issues like Energy saving measures and Transport policies.
With regard to renewable energy production, the visual intrusion of wind turbines and solar panels should remain a determining factor within and adjacent to the National Park and local or National Park Authority planning controls should not be overridden by Central Government dictates. However, suitable alternative green solutions, such as hydro-electricity and small-scale wind power generation and discreet solar installations should be considered and encouraged with appropriate financial incentives.
Government-backed energy-saving advisory and grant schemes should take full account of the special character of the National Park and the traditional-built nature of its existing housing stock. We would support a specific and tailored scheme offering help to home owners and rental property landlords within the National Park.
The opportunities for small-scale, light industrial development should also take account of the National Parks special circumstances and encourage suitable employment opportunities within the Park, without the need to travel long distances to work. This also applies to the provision of the technological infrastructure.
New tourism developments should, as far as possible, be sustainable in all aspects of their operation, including encouraging the use of public transport for visitors.
There should be an integrated public transport system for the National Park which allows for transport hubs with ample parking facilities or rail links around the periphery of the National Park and a network of low carbon or carbon-neutral buses and cycle ways with adjacent hire facilities, along with electric vehicle charging facilities.
We strongly believe in the environmental as well as social and economic value of traditional and sustainable farming to Dartmoor and support the marketing and sale of locally-produced food of all kinds over imported and processed food, especially where this involves substantial food miles, poorer welfare and quality standards and impacts on the environment and wellbeing of local populations in other parts of the world. These issues need to be assessed holistically when considering large-scale ‘re-wilding’ initiatives where substantial areas of land are taken out of food production altogether, lest there are unintended or unknown knock-on consequences.
We believe that maintaining appropriate stocking levels on the commons not only helps to control species such as Molinia, gorse and bracken that are less beneficial to a healthy biodiversity but, if well-managed in rotation, also help the process of carbon sequestration and healthy biodiversity.
We recognise the potential benefits of conserving blanket peat in order to sequester and store more carbon and support projects that give nature a helping hand in the process of regeneration. However, we feel that more account needs to be taken of carbon and methane released as a consequence of the works themselves and that the creation of large areas of deep water on exposed hill tops might actually lead to a reduced efficiency in carbon sequestration.
While we are in favour of native, broad-leafed tree planting and encouraging natural regeneration by the exclusion of livestock (and people) exclusion from agreed areas, we are concerned about the impact of wholesale tree planting over large areas of the uplands as a means of carbon trading as this is not only historically alien to this environment (the Forest of Dartmoor was never a forest!) but trees are ten times less efficient at carbon sequestration than peat.
In our view – based on the knowledge and experience of our farming members and other long-term observations – the overall substantial reduction of livestock numbers over the past thirty years has led to the rising dominance of Molinia, gorse and bracken.
We are concerned by the increasing demand for housing and second homes, both on and around Dartmoor, following the pandemic, not only for the impact this will have on local housing needs and affordability but the consequent pressure for new development and the impact this will have on the local infrastructure and road networks and, in turn, climate change.
With regard to our own Society activities, we undertake to reduce our carbon footprint by holding more video conference meetings and events and by encouraging lift sharing or the use of public transport for any members’ activities and by offering more online services, for example, using the website, emails and social media to disseminate information and news to members and the wider public where possible and not detrimental to members without access to the necessary technology.
Alan Endacott, July 2021
Posted in Responses/Comments on Sunday 21st November 2021 at 8:43am
You can see the side by side comparison of proposed and existing byelaws and other reference material on the DNPA website.
The wording of the Dartmoor Society’s covering letter follows, together with a link to download the actual submission.
The Dartmoor Society Executive Committee have considered the draft proposals for changes to the Dartmoor National Park Authority Byelaws, taking on board a number of viewpoints to try and reach on consensus on each of the proposals. Where there have been conflicting opinions, we have sought the majority view. Our resulting specific comments are attached herewith. These have also been posted online.
As a general point, the use of pronouns should be non-gender specific.
With regard to the need for revision of the existing Byelaws, we welcome the proposals and consultation exercise although we regret that it has taken the unprecedented pressures brought about by the pandemic to highlight weaknesses in the current rules and their enforcement. The other issue that has become apparent with the influx of additional visitors has been a lack of knowledge of the byelaws applicable to Dartmoor’s access land or an understanding of the reasons behind them and even a basic awareness of the Country Code and, while we applaud the ongoing efforts of the Ranger service and Visitor Centre staff on the ground as well as your education and outreach teams, clearly more needs to be done to get the message through to these new visitors before they arrive, or when they move to the region, in order to provide education on the rules and the issues concerned in an effective way and this will require significantly more resources in future.
In many regards we agree with the views of the Dartmoor Preservation Association, particularly the need for better enforcement, although we may differ on a few specific issues, as can be seen from our attached comments. We also agree that a long-term view needs to be taken as we emerge from the specific problems brought about by the pandemic. These should take into account the consequences of increasing recreational pressure resulting from greater urbanisation around the periphery of the Park as well as the impact of increased activity that might impact on the existing infrastructure, air and water quality, climate change and the decline of species.
In terms of parking, we would also not wish to see a proliferation of signage and alternative means of controlling verge parking should be considered, such as positive signage on main approaches stating that parking should only be in designated areas, where discreet signage indicates that you can park.
One of the key differences to the DPA’s view is on the proposal that dogs should be kept on a lead during the ground nesting bird season under 10(iii). We also had much debate on the issue, with compromises suggested but, in the end, the majority view was that only a total ban as proposed would be fair and enforceable and that the Sandford Principle should apply.
Ultimately, the effectiveness of the new byelaws will come down to good education and enforcement, and we trust that these areas will also be under review and allocated sufficient resources, otherwise the exercise will be a waste of time and money.
Alan Endacott MA
Acting Chair, The Dartmoor Society
Posted in Responses/Comments on Wednesday 14th October 2020 at 10:24pm
You may have seen recent press reports regarding Natural England requiring all sheep to be removed from Okehampton Commons over the winter. This, of course, would be breaking a two hundred-year-old tradition of year-round grazing and cause very real problems for the commoners concerned, potentially putting them out of business and leading to the complete loss of livestock. This in turn would have a devastating impact on the well-established ecology of a large tract of moorland and the delicate ecological balance and diversity of the SSSI, without the positive benefits of conservation grazers.
I immediately wrote to the Natural England Team Manager, Eamon Crowe, to raise our concerns and reiterate the Dartmoor Society’s position regarding the value of maintaining traditional management practices and the dangers of significant reductions of mixed grazing. I urged them to meet with the commoners as soon as possible to clarify the situation and negotiate sustainable levels of livestock, while listening to local knowledge and wisdom regarding the practical issues involved with animal husbandry that make it very difficult to meet the expectations of ecologists without constructive dialogue and compromise.
He wrote back and said “I accept all you say below and I can assure you that it not the intention of NE and I have had 26 years of experience on Dartmoor not to let this happen.” There has evidently been a misunderstanding between the two parties and I was told that they were “in the middle of negotiations”.
We will continue to monitor the situation as the outcome may have ramifications for the rest of the Dartmoor Commons. Our policy is to encourage positive and constructive debate on the issues between parties, based on sound research and objective evidence. As well as academic studies, we feel strongly that such evidence should include anecdotal and photographic comparisons going back decades as well as previous vegetation surveys.
As a consequence of the Gidleigh Common Day, organised by the Society in August 2018, a winter cattle grazing trial was instigated. We had hoped to be able to follow this up this summer to receive reports on its effectiveness and to witness the results on the ground but this has had to be put on hold until Covid restrictions allow, all being well, next summer. We were also looking forward to hearing Eamon Crowe speak from the Natural England perspective at our postponed AGM in April this year and, again, we hope to reschedule this in the New Year.
With increasing concerns over climate change and accelerating loss of species, it is more important than ever that all parties understand each other’s perspectives and the practical issues and talk constructively rather than simply make public criticism. We will always endeavour to broker constructive, face-to-face negotiations, based on sound reason and common sense rather than risk stirring up hostility in such a way.
Alan Endacott, Acting Chairman
The Dartmoor Society
Posted in Responses/Comments on Monday 11th May 2020 at 10:05pm
The revised comments below were recently submitted to Dartmoor National Park by our Acting Chairman, Alan Endacott, as The Dartmoor Society’s official response to the Management Plan Review.
The Dartmoor Society broadly supports the vision underpinning the Management Plan and we feel that the overall balance of the Plan itself is fair and demonstrates a genuine willingness to consult with interested parties and to listen to their views.
It should be stated at the outset that we agree on far more than we disagree on and that the following comments should, therefore, be seen in that context. Where no comment is made on a specific topic or proposal it should be assumed that we are broadly in agreement.
We congratulate the Authority on its own efforts to become carbon neutral by 2025. However, while Dartmoor itself has much to offer in mitigating the effects of climate change regionally, we see certain risks in Dartmoor being seen as the carbon sink for the rest of Devon, especially when it comes to investment from conscience-driven carbon offset schemes. Such activity (such as mass tree planting on peatlands or open moorland) needs to be carefully planned and controlled in order to derive the greatest benefits and to avoid unintended knock-on consequences rather than being largely driven by available funding.
We have similar reservations about some of the current ‘upstream thinking’ policies, including the damming of streams and peatland ‘restoration’. The Society still disputes the historical context of peat denudation on the uplands. We do accept that there are clearly potential carbon gains and other environmental benefits from the consolidation of blanket peat cover but only where it is clearly demonstrated that nature needs a helping hand. We remain opposed to the current overly invasive methodology. Instead, we would prefer to see a softer, more phased approach to the work, for instance, the manual placing of pre-seeded sphagnum in biodegradable nets to form dams and shallow pools to encourage the gradual establishment of sphagnum bog over a greater area, rather than the current use of excavators and intrusive dams that risk releasing more harmful methane than the carbon gains are worth and create deep pools, with the attendant physical and health risks to wildlife and livestock.
With regards to sustainable transport, although there is going to be an increasing demand for vehicle charging points and other infrastructure to accommodate low-carbon transport, it will prove almost impossible to cope with the sheer predicted numbers of electric vehicles in the future and we feel the Authority should take bold steps, along with public and private partners, to aim for a fully integrated public transport system to reduce the number of visitors arriving in cars as well as helping local communities to reduce their car usage. For instance, a network of affordable ‘Park and Ride’ facilities around the outskirts of the National Park, operating with low-carbon buses. Dartmoor could become an exemplar of what can be achieved.
When public infrastructure improvements are considered to provide low-carbon facilities, these should not be limited to vehicle charging points and other technologies, such as hydrogen, should be taken into account, especially around the periphery of the National Park. Flexibility should be built in to any project plans to take account of new or emerging technologies and the specific needs of Dartmoor communities, which will, of course, be quite different to more urban areas, should always be taken into account.
We welcome the National Park’s commitment to reducing energy consumption through improved building efficiency and the use of small-scale renewable and low-carbon energy technologies and hope that the resources can be made available to back this up. Given that much of Dartmoor’s existing housing stock is of traditional construction and few rural settlements have access to mains gas, there is significant fuel poverty and insulation and heating bring particular challenges, especially with the current high costs of renewable technologies and planning restrictions on their introduction in a National Park. In recognition of this, it would be helpful if there were a specific scheme, administered by the National Park Authority, to draw on Government incentives and advice for home owners and landlords, to take account of the special circumstances of the National Park.
While we welcome the aim of including young people in decision making, we feel that this is an issue that relates to all ages with respect to the lack of democratic representation of residents on the National Park Authority, in particular relating to planning issues. However, we acknowledge that this is beyond the scope of this Plan and recognise the willingness of the Authority to listen to the views of all stakeholders in order to shape their decisions.
We share the concerns regarding affordable housing, jobs and skills and would welcome any practical encouragement of traditional skills and knowledge being passed on as well as the other ideas put forward.
We regret the loss of County Council ‘starter farms’ within the National Park and the opportunities they provided for young farmers to get established. If it isn’t already, this kind of opportunity should be borne in mind in relation to Duchy tenancies, with a certain quota specifically for young farmers starting out. How this could be subsidised could be the subject of the new ELMS principles.
Part of the process of young people learning about what is special and how to help conserve and enhance it should be to encourage dialogue with the older generation in order to perpetuate the cycle of received wisdom and experience that is so often overlooked by decision makers who, thus, either re-invent the wheel or repeat the mistakes of the past.
We are a little uncomfortable about the idea of waymarked routes. This can be achieved in theory using GPS technology without the need for intrusive way-markers but, in any case, a big part of the Dartmoor experience is learning how to map read and to enjoy orienteering and using one’s other senses and these skills should be encouraged in younger people rather than risk being overly protective.
There is possibly a need to define what is meant by ‘natural beauty’ as much of what is popularly seen as the ‘wilderness’ of Dartmoor is, in fact, the product of human intervention over thousands of years. While we accept that there is an important place for nature reserves and a patchwork of different habitats with different degrees of management, if left totally to nature, much of Dartmoor would become inaccessible and it is important that this message gets across to the wider public.
For instance, there is a tendency for people unfamiliar with Dartmoor’s history to misconstrue the meaning of the historical term ‘Forest of Dartmoor’ and demand that trees should be re-planted on the uplands in order to ‘re-wild’ it. Apart from the fact that broadleaved trees would be unlikely to grow in the prevailing soils and conditions, they would be nowhere near as efficient at carbon sequestration as peat.
Presumably the proposed landscape-scale ‘nature recovery areas’ will involve the exclusion of people and livestock? We are not necessarily against the principle where there is a clear and demonstratable need but we would be interested to see any specific proposals in due course.
There is also a strong case to be made for bracken and gorse clearance/control and a return to pre Foot and Mouth stocking levels and allowing and encouraging appropriate overwintering of cattle once more in order to reverse the current overdominance of bracken, gorse and Molinia in many areas and to restore the previous biodiversity through better management of the commons by livestock. Bracken is especially problematic in connection with the spread of Lyme disease but also hides (and may even damage) archaeological remains for much of the year, is poisonous to livestock and carcinogenic.
We are supportive of the coordinated approach of the Dartmoor Fires Partnership to tackle the increasing risk of wildfires. However, prevention is clearly the best policy and we would like to see a similar approach to controlled swaling of the commons, providing individual commoners associations are fully involved and in agreement. We believe that, as well as a more strategic approach being applied in order to control vegetation and reduce the risk of wild fires in the first place, a more flexible approach is needed within the overall agreed framework, for instance, where the weather prevents planned burns or an outbreak of heather beetle is noted.
We applaud the emphasis placed on Dartmoor’s cultural heritage and, in particular, the desire to see that the significance of Premier Archaeological Landscapes (PALs) is recognised by other agencies and given a degree of statutory standing. We would like this to have a similar weighting to SSSIs and other conservation designations. However, we note the reference to potential conflicting priorities and the need for a process for assessing strategic environment priorities to guide decision making in relation to other conservation objectives. We trust that extreme caution will be exercised when setting priorities and precedents and that there will be appropriate consultation with all interested parties.
We welcome the principle of a rolling survey of listed buildings and quinquennial buildings at risk survey and hope that sufficient resources are made available or sought to assist the process and to help with any remedial conservation work required, in partnership with owners and other agencies.
Dartmoor’s international importance to prehistoric archaeology deserves a corresponding level of resource. The encouragement of pro-active research into the Moor’s cultural heritage is very welcome, as is the ongoing work with local communities and volunteers.
As this Plan is about vision, ultimately we would like to see it go further and recognise the ecocultural value of all of the open Moor by abandoning distinctions between what is considered to be of particular ecological or cultural merit and the often arbitrary boundaries of SSSIs, PALs and other statutory designations, in favour of a single ecocultural designation in full recognition of the equal and symbiotic value of both. We would hope that this would ensure a more even distribution of resources and management to a consistent high quality.
We are broadly happy with the general principles and aims set out in the Management Plan – subject to the previous comments regarding winter grazing for cattle and the need to redress the balance due to under-grazing, the lack of timely swaling on many commons over recent years and the consequent over-dominance of various species (including bracken, gorse and Molinia). The rise of Molinia in particular has knock-on consequences for the environment as the dense thatch effect produced when it dies down in the winter increases run-off and reduces the ability of the soil beneath to absorb carbon.
As well as recognising the conservation benefits of sustainable farming, we also feel that due consideration should always be given to the importance of home food production over importation, with its additional food miles and ethical considerations, such as forest clearance, the local impact of cash-crop production in the developing world and often poorer animal welfare standards. Taking good farmland out of efficient production here will inevitably have a knock-on effect on other parts of the world and this aspect should always be part of the carbon offset equation. There is little point in planting thousands of trees on good pasture land for instance if a similar area of rainforest is being cleared in South America in order to produce beef for export to the UK on a carbon-fuelled freighter!
The bottom-up approach to the Farming Futures and Dartmoor Hill Farm Projects is an exemplar of what can be achieved in partnership and it would be good to see this extended to the whole of the National Park, or the commons at least.
The detailed delivery of these aims and policies will, no doubt, be the subject of much discussion between farmers and the various agencies involved over the life of the Plan and as the post-Brexit situation becomes clearer. The Dartmoor Society will be pleased to take part in such discussions where appropriate and helpful. We have a Hill Farming Sub-committee, looking in more detail at issues affecting farming in the National Park and the Society’s position on such matters.
It may be of interest to note that the Society already organise regular farm and woodland visits and that these are reported on our website and in the members’ thrice-yearly Newsletter.
With regard to visitor pressure on the roads, see comments above regarding a sustainable transport network.
We feel that there is a conflict between the promotion of Dartmoor as a physical activity playground and a suitable place for potentially destructive pastimes, such as foraging, and the long-term well-being of the environment and local communities. While we respect the rights of individuals to legally indulge in such pastimes, we don’t think they should be widely promoted in the media (e.g. BBC Countryfile) and marketing campaigns and should not be actively promoted by the National Park Authority.
Equally, the emphasis should be on managing, encouraging and educating those who wish to visit the National Park of their own volition rather than campaigns to increase overall visitor numbers. There are some excellent examples of sustainable tourism models within the National Park and these should continue to be encouraged, as should initiatives to help underprivileged groups (such as CHICKS or the Jubilee Challenge) to enjoy and feel inspired by the experience.
We are concerned about the increasing number of large-scale events being staged in the National Park, the damage they can cause and the impact on local communities and farmers. We feel that there are insufficient controls and opportunities for those communities and farmers affected to have their say.
Recent years have seen increasing numbers of closures of banks and Post Offices, not only in rural areas but in the larger towns that service Dartmoor communities. This is causing significant hardships to individuals and communities as well as to the surviving Sub-Postmasters who are having to take on more work, including outreach services to villages that have already lost their Post Offices, for little extra money. It also means that, with a lack of public transport, people are being forced to drive (or be driven) significant distances to transact their affairs and this also leads to an increasing sense of isolation for those who can't travel.
Poor reception for mobile phones and slow internet connections for those who can use online facilities (and there are still many, particularly elderly residents, who can’t) exacerbates the problem. There needs to be a Dartmoor-wide strategy to protect such vital community services.
Unfortunately, part of the problem is that the viability of many service and retail businesses within the National Park is affected by the increasing tendency for new residents to commute and have little to do with the local community. This is in part a cultural issue as many choose not to mix or get involved, not having experienced village life before. Obviously, this is a personal choice but needs to be taken into account in the consideration of support for businesses and community initiatives and ways of changing perceptions.
The examples given in the introduction are a little provocative – presumably deliberately so. However, the semantics are dangerous and run the risk of undoing all the goodwill engendered through the consultation process and undermining any subsequent consensus. It could be interpreted as a power of veto and that, regardless of whatever anybody else says, at the end of the day ‘Nanny knows best’.
Of course, as with all plans, the devil will be in the detail and any general statements may give the wrong impression but they appear to pre-suppose that environmental ‘improvement’ will always take priority over all other aspects of the landscape and so a cultural landscape that may be thousands of years old and is ‘considered to be of international significance’ is seen as less important than whatever the current fashion of environmental management or ‘enhancement’ is. This could be seen as rather an arrogant proposition and the justification open to dispute.
The term ‘nature recovery’ itself is actually a culturally loaded term as it presupposes that the flora and fauna of an inherited, culturally managed landscape isn’t ‘natural’ and, by imposing the exclusion of large mammals (including humans), we are making a cultural choice rather than leaving it to nature. Having said that, we aren’t necessarily against the idea and the unaided re-generation of valley-side woodland is clearly particularly effective. We simply want to see that in individual cases, all angles and views are taken into account with open minds.
Having said all of that, the succeeding assessment of the challenges and issues is fair and balanced overall and we would respectfully suggest that the introduction is revised to reflect the overall consensus rather than concentrate on potential conflicts.
Additional indicators could include:
Posted in Responses/Comments on Monday 6th April 2020 at 9:42pm
The comments below were recently submitted to Dartmoor National Park by our Acting Chairman, Alan Endacott, as The Dartmoor Society’s official response to the Management Plan Review.
The Dartmoor Society broadly supports the vision underpinning the Management Plan and we feel that the overall balance of the Plan itself is fair and demonstrates a genuine willingness to consult with interested parties and to listen to their views.
It should be stated at the outset that we agree on far more than we disagree on and that the following comments should, therefore, be seen in that context. Where no comment is made on a specific topic or proposal it should be assumed that we are broadly in agreement.
We congratulate the Authority on its own efforts to become carbon neutral by 2025. However, while Dartmoor itself has much to offer in mitigating the effects of climate change regionally, we see certain risks in Dartmoor being seen as the carbon sink for the rest of Devon, especially when it comes to investment from conscience-driven carbon offset schemes. Such activity (such as mass tree planting on peatlands or open moorland) needs to be carefully planned and controlled in order to derive the greatest benefits and to avoid unintended knock-on consequences rather than being largely driven by available funding.
We have similar reservations about some of the current ‘upstream thinking’ policies, including the damming of streams and peatland ‘restoration’. The Society still disputes the historical context of peat denudation on the uplands but we do accept that there are clearly potential carbon gains and other environmental benefits from the consolidation of blanket peat cover. However, we remain opposed to the current overly invasive methodology. Instead, we would prefer to see a softer, more phased approach to the work, for instance, the manual placing of pre-seeded sphagnum in biodegradable nets to form dams and shallow pools to encourage the gradual establishment of sphagnum bog over a greater area, rather than the current use of excavators and intrusive dams that risk releasing more harmful methane than the carbon gains are worth and create deep pools, with the attendant physical and health risks to wildlife and livestock.
With regards to sustainable transport, although there is going to be an increasing demand for vehicle charging points and other infrastructure to accommodate low-carbon transport, it will prove almost impossible to cope with the sheer predicted numbers of electric vehicles in the future and we feel the Authority should take bold steps, along with public and private partners, to aim for a fully integrated public transport system to reduce the number of visitors arriving in cars as well as helping local communities to reduce their car usage. For instance, a network of affordable ‘Park and Ride’ facilities around the outskirts of the National Park, operating with low-carbon buses. Dartmoor could become an exemplar of what can be achieved.
When public infrastructure improvements are considered to provide low-carbon facilities, these should not be limited to vehicle charging points and other technologies, such as hydrogen, should be taken into account, especially around the periphery of the National Park. Flexibility should be built in to any project plans to take account of new or emerging technologies and the specific needs of Dartmoor communities, which will, of course, be quite different to more urban areas, should always be taken into account.
We welcome the National Park’s commitment to reducing energy consumption through improved building efficiency and the use of small-scale renewable and low-carbon energy technologies and hope that the resources can be made available to back this up. Given that much of Dartmoor’s existing housing stock is of traditional construction and few rural settlements have access to mains gas, there is significant fuel poverty and insulation and heating bring particular challenges, especially with the current high costs of renewable technologies and planning restrictions on their introduction in a National Park. In recognition of this, it would be helpful if there were a specific scheme, administered by the National Park Authority, to draw on Government incentives and advice for home owners and landlords, to take account of the special circumstances of the National Park.
While we welcome the aim of including young people in decision making, we feel that this is an issue that relates to all ages with respect to the lack of democratic representation of residents on the National Park Authority, in particular relating to planning issues. However, we acknowledge that this is beyond the scope of this Plan and recognise the willingness of the Authority to listen to the views of all stakeholders in order to shape their decisions.
We share the concerns regarding affordable housing, jobs and skills and would welcome any practical encouragement of traditional skills and knowledge being passed on as well as the other ideas put forward.
We regret the loss of County Council ‘starter farms’ within the National Park and the opportunities they provided for young farmers to get established. If it isn’t already, this kind of opportunity should be borne in mind in relation to Duchy tenancies, with a certain quota specifically for young farmers starting out. How this could be subsidised could be the subject of the new ELMS principles.
Part of the process of young people learning about what is special and how to help conserve and enhance it should be to encourage dialogue with the older generation in order to perpetuate the cycle of received wisdom and experience that is so often overlooked by decision makers who, thus, either re-invent the wheel or repeat the mistakes of the past.
We are a little uncomfortable about the idea of waymarked routes. This can be achieved in theory using GPS technology without the need for intrusive way-markers but, in any case, a big part of the Dartmoor experience is learning how to map read and to enjoy orienteering and using one’s other senses and these skills should be encouraged in younger people rather than risk being overly protective.
There is possibly a need to define what is meant by ‘natural beauty’ as much of what is popularly seen as the ‘wilderness’ of Dartmoor is, in fact, the product of human intervention over thousands of years. While we accept that there is an important place for nature reserves and a patchwork of different habitats with different degrees of management, if left totally to nature, much of Dartmoor would become inaccessible and it is important that this message gets across to the wider public.
For instance, there is a tendency for people unfamiliar with Dartmoor’s history to misconstrue the meaning of the historical term ‘Forest of Dartmoor’ and demand that trees should be re-planted on the uplands in order to ‘re-wild’ it. Apart from the fact that broadleaved trees would be unlikely to grow in the prevailing soils and conditions, they would be nowhere near as efficient at carbon sequestration as peat.
Presumably the proposed landscape-scale ‘nature recovery areas’ will involve the exclusion of people and livestock? We are not necessarily against the principle where there is a clear and demonstratable need but we would be interested to see any specific proposals in due course.
There is also a strong case to be made for bracken and gorse clearance/control and a return to pre Foot and Mouth stocking levels and allowing and encouraging appropriate overwintering of cattle once more in order to reverse the current overdominance of bracken, gorse and Molinia in many areas and to restore the previous biodiversity through better management of the commons by livestock. Bracken is especially problematic in connection with the spread of Lyme disease but also hides (and may even damage) archaeological remains for much of the year, is poisonous to livestock and carcinogenic.
We are supportive of the coordinated approach of the Dartmoor Fires Partnership to tackle the increasing risk of wildfires. However, prevention is clearly the best policy and we would like to see a similar approach to controlled swaling of the commons, providing individual commoners associations are fully involved and in agreement. We believe that, as well as a more strategic approach being applied in order to control vegetation and reduce the risk of wild fires in the first place, a more flexible approach is needed within the overall agreed framework, for instance, where the weather prevents planned burns or an outbreak of heather beetle is noted.
We applaud the emphasis placed on Dartmoor’s cultural heritage and, in particular, the desire to see that the significance of Premier Archaeological Landscapes (PALs) is recognised by other agencies and given a degree of statutory standing. We would like this to have a similar weighting to SSSIs and other conservation designations. However, we note the reference to potential conflicting priorities and the need for a process for assessing strategic environment priorities to guide decision making in relation to other conservation objectives. We trust that extreme caution will be exercised when setting priorities and precedents and that there will be appropriate consultation with all interested parties.
We welcome the principle of a rolling survey of listed buildings and quinquennial buildings at risk survey and hope that sufficient resources are made available or sought to assist the process and to help with any remedial conservation work required, in partnership with owners and other agencies.
Dartmoor’s international importance to prehistoric archaeology deserves a corresponding level of resource. The encouragement of pro-active research into the Moor’s cultural heritage is very welcome, as is the ongoing work with local communities and volunteers.
We are broadly happy with the general principles and aims set out in the Management Plan – subject to the previous comments regarding winter grazing for cattle and the need to redress the balance due to under-grazing, the lack of timely swaling on many commons over recent years and the consequent over-dominance of various species (including bracken, gorse and Molinia). The rise of Molinia in particular has knock-on consequences for the environment as the dense thatch effect produced when it dies down in the winter increases run-off and reduces the ability of the soil beneath to absorb carbon.
As well as recognising the conservation benefits of sustainable farming, we also feel that due consideration should always be given to the importance of home food production over importation, with its additional food miles and ethical considerations, such as forest clearance, the local impact of cash-crop production in the developing world and often poorer animal welfare standards. Taking good farmland out of efficient production here will inevitably have a knock-on effect on other parts of the world and this aspect should always be part of the carbon offset equation. There is little point in planting thousands of trees on good pasture land for instance if a similar area of rainforest is being cleared in South America in order to produce beef for export to the UK on a carbon-fuelled freighter!
The bottom-up approach to the Farming Futures and Dartmoor Hill Farm Projects is an exemplar of what can be achieved in partnership and it would be good to see this extended to the whole of the National Park, or the commons at least.
The detailed delivery of these aims and policies will, no doubt, be the subject of much discussion between farmers and the various agencies involved over the life of the Plan and as the post-Brexit situation becomes clearer. The Dartmoor Society will be pleased to take part in such discussions where appropriate and helpful. We have a Hill Farming Sub-committee, looking in more detail at issues affecting farming in the National Park and the Society’s position on such matters.
It may be of interest to note that the Society already organise regular farm and woodland visits and that these are reported on our website and in the members’ thrice-yearly Newsletter.
With regard to visitor pressure on the roads, see comments above regarding a sustainable transport network.
We feel that there is a conflict between the promotion of Dartmoor as a physical activity playground and a suitable place for potentially destructive pastimes, such as foraging, and the long-term well-being of the environment and local communities. While we respect the rights of individuals to legally indulge in such pastimes, we don’t think they should be widely promoted in the media (e.g. BBC Countryfile) and marketing campaigns and should not be actively promoted by the National Park Authority.
Equally, the emphasis should be on managing, encouraging and educating those who wish to visit the National Park of their own volition rather than campaigns to increase overall visitor numbers. There are some excellent examples of sustainable tourism models within the National Park and these should continue to be encouraged, as should initiatives to help underprivileged groups (such as CHICKS or the Jubilee Challenge) to enjoy and feel inspired by the experience.
We are concerned about the increasing number of large-scale events being staged in the National Park, the damage they can cause and the impact on local communities and farmers. We feel that there are insufficient controls and opportunities for those communities and farmers affected to have their say.
Recent years have seen increasing numbers of closures of banks and Post Offices, not only in rural areas but in the larger towns that service Dartmoor communities. This is causing significant hardships to individuals and communities as well as to the surviving Sub-Postmasters who are having to take on more work, including outreach services to villages that have already lost their Post Offices, for little extra money. It also means that, with a lack of public transport, people are being forced to drive (or be driven) significant distances to transact their affairs and this also leads to an increasing sense of isolation for those who can’t travel.
Poor reception for mobile phones and slow internet connections for those who can use online facilities (and there are still many, particularly elderly residents, who can’t) exacerbates the problem. There needs to be a Dartmoor-wide strategy to protect such vital community services.
Unfortunately, part of the problem is that the viability of many service and retail businesses within the National Park is affected by the increasing tendency for new residents to commute and have little to do with the local community. This is in part a cultural issue as many choose not to mix or get involved, not having experienced village life before. Obviously, this is a personal choice but needs to be taken into account in the consideration of support for businesses and community initiatives and ways of changing perceptions.
The examples given in the introduction are a little provocative – presumably deliberately so. However, the semantics are dangerous and run the risk of undoing all the goodwill engendered through the consultation process and undermining any subsequent consensus. It could be interpreted as a power of veto and that, regardless of whatever anybody else says, at the end of the day ‘Nanny knows best’.
Of course, as with all plans, the devil will be in the detail and any general statements may give the wrong impression but they appear to pre-suppose that environmental ‘improvement’ will always take priority over all other aspects of the landscape and so a cultural landscape that may be thousands of years old and is ‘considered to be of international significance’ is seen as less important than whatever the current fashion of environmental management or ‘enhancement’ is. This could be seen as rather an arrogant proposition and the justification open to dispute.
The term ‘nature recovery’ itself is actually a culturally loaded term as it presupposes that the flora and fauna of an inherited, culturally managed landscape isn’t ‘natural’ and, by imposing the exclusion of large mammals (including humans), we are making a cultural choice rather than leaving it to nature. Having said that, we aren’t necessarily against the idea and the unaided re-generation of valley-side woodland is clearly particularly effective. We simply want to see that in individual cases, all angles and views are taken into account with open minds.
Having said all of that, the succeeding assessment of the challenges and issues is fair and balanced overall and we would respectfully suggest that the introduction is revised to reflect the overall consensus rather than concentrate on potential conflicts.
Additional indicators could include:
Posted in Responses/Comments on Tuesday 25th February 2020 at 11:01pm
Dartmoor Society member Tony Hill writes:
“Just in case you haven’t already seen, the Government has given more details of the process for bidding for the £500 million “Beeching Reversal Fund” which is intended to fund studies to investigate which lines it is worth reopening.
The process is to be initiated by MPs and the deadlines are pretty tight. The first call is for expressions of interest for the “Ideas Fund” by Friday 28th February, with at least one more round to follow.
Devon County Council has already announced that they are to bid for money to help finish the plans to reopen Bere Alston to Tavistock. That’s a different part of the fund – the “Accelerating Existing Proposals” bit.
A group has been set up by rail journalist Andy Roden with the aim of putting the whole Northern Route forward for consideration – Bere Alston to Meldon Quarry inclusive.
Geoffrey Cox is the key to getting a bid in. He has to at least submit the expression of interest.
Dartmoor Society members living in the area within the reinstated through route (closed on 6/5/1968) would serve, particularly those in West Devon who are interested in this project, are invited to email Geoffrey Cox about the fund and propose that he will make sure that not just Bere Alston to Tavistock but the whole Northern Route is fully considered.”
Geoffrey Cox’s email address is: tellgeoffrey@geoffreycox.co.uk.
Posted in Responses/Comments on Thursday 7th February 2019 at 11:17pm
We recommend that there should be an introductory section to the Local Plan which informs the reader that the Plan is essentially concerned with the environment and communities of the enclosed landscape beyond the open moorland. It is extremely rare that there are any planning applications affecting open moorland (examples might be for replacement military structures or Mires Project paraphernalia. Proposals for large-scale infrastructure such as reservoirs, roads, mineral workings or windfarms are very unlikely).
This section mentions ‘evidence’ and ‘data’. We recommend that it should include an aspiration for all data relating to biodiversity, cultural diversity and the social fabric of Dartmoor to be freely and straightforwardly accessible online for everyone, using each parish as a framework.
We welcome this policy but with a sense of deep irony, given the recent hostile treatment of the National Park towards Steward Community Woodland and Hillyfield, both of which are exemplars of sustainable development.
We recommend that additional settlements are included under this categorye.g. Buckland-in-the-Moor, Doccombe, Gidleigh, Harford, Haytor, Leusdon, Murchington, Poundsgate, Sampford Spiney, Teign Village
Delete ‘of’ from heading.
We recommend that this should include woodland management.
This section (1.6.3) should include a statement about the importance of 20th and 21st century buildings that have contributed to the life and work of Dartmoor communities and which continue the legacy of the human story of Dartmoor. Especially important are those buildings of the first half of the 20th century, i.e. before the creation of the National Park, such as small-scale bungalows.
What is ‘natural surveillance’?
We welcome mention of ‘corrugated metal sheeting’.
‘Figure 1.1.’ should read ‘Figure 1.3’.
We recommend that this policy should include a statement that ‘materials of timber and stone should be locally sourced wherever possible’.
We recommend that there should be a statement and a clear map which distinguishes between those designations on the open moorland and those within enclosed land, as the latter are the most relevant to the Local Plan and development (see comment on p.6, above).
We recommend that there should be a statement about the key importance of ‘ordinary’ and commonplace species rather than an emphasis only on the rare or unusual. There will almost always be a net loss of commonplace biodiversity when there is new development, especially on greenfield sites.
We recommend that there should be a statement noting that many of the negative impacts on Dartmoor biodiversity are caused by development and population pressure outside the National Park, within Devon, Britain and abroad.
We recommend that the concept of ‘enhancement’ should include ‘Cultural Enhancement’ alongside ‘Biodiversity Enhancement’. This would relate to the loss of historic hedges and other cultural features including structures.
‘Swale’ is not a Dartmoor term, and should be deleted or replaced. It is North American dialect for a marshy depression, probably borrowed from eastern England in the 17th century (Source: Wikipedia).
We recommend that this section should include a statement about the importance of centuries of woodland management on Dartmoor which have created features of cultural significance (structures, boundaries, tracks etc) within them.
We recommend, under 2.5.2 that there should be an additional bullet-point:
We recommend that the statement about 1,082 Scheduled Monuments should be rewritten. Approximately 1,000 of these are on moorland which is most unlikely to have development proposals [this estimate was provided orally and informally to Tom Greeves by Andy Crabb in January 2019]. Moreover, the Scheduled Monuments on moorland are not indicative of the overall scale of culturally significant features on moorland, nor do they have a realistic protective role (unlike the designations within enclosed land), and confuse attitudes towards the historic environment. Readers of the Local Plan will be interested to know where the 80 or so Scheduled Monuments are within enclosed land, and there should be a map indicating these.
We recommend that this section includes a statement to the effect that all buildings (whether ancient or newly built) have ‘heritage’ value as they tell parts of the human story of Dartmoor over centuries or millennia. It is obvious that medieval buildings are important but there needs to be recognition of the importance of more recent structures too, especially those of the 19th and 20th centuries which may not be designated as listed buildings.
PALs do not adequately reflect the extent and time-depth of the human story on moorland and so confuse conservation thinking, and have failed to benefit the archaeology of moorland Dartmoor. They are not relevant to the enclosed landscape which the Local Plan is focussed on.
We recommend an aspiration to provide high quality data about the built environment, parish by parish, freely available online (see comment p.17 1.2, above).
We recommend that a new bullet-point is added for ‘woodlands’ as key areas for potential new discoveries.
We recommend that a new bullet-point is added for ‘mills, weirs and watercourses’.
We recommend that under the fourth current bullet-point that ‘industrial housing’ is added within the bracket.
We recommend that the list of ‘Areas of Historic Setting’ is expanded to include, for example, Horndon as a distinctive mining zone.
The final sentence in this paragraph is ungrammatical. There needs to be a fullstop after ‘conversion’, and the start of a new sentence with ‘Unfortunately’.
We welcome the statement that ‘Generally the more a building changes the more its character is lost’ but we recommend that this principle is applied to all residential buildings and new-builds (see 3.7, below) with regard to extensions.
Caution is needed with the term ‘traditional’ unless clearly defined, as features of the 20th and even 21st century are ‘traditional’ in some sense or can become so. Therefore we recommend that this policy is rewritten as follows: ‘of a form, structure and history that significantly informs the story of Dartmoor’s built heritage’.
65 new homes per annum equate to 650 new homes within a decade which, almost certainly, will result in a significant increase in population. Although there has been little change to Dartmoor’s population in the past 10 years, we recommend that there should be a statement of national, regional and local population trends (relentlessly upwards) which are bound to impact upon Dartmoor.
We recommend that the sixth current bullet-point should have ‘woodland’ added, as ‘forestry’ implies commercial non-native forestry activity.
We recommend that a new bullet-point is added: ‘Support small-scale quarrying, micro-hydro schemes, and re-use of railways’.
We are concerned at the increase in second homes and we recommend that there should be a ‘principal residence’ requirement/condition on all existing homes as well as new housing.
We welcome para 3.7.3 regarding the negative impact of extensions, which destroy the original integrity of a building (see comment p.48 re 2.7.5.3, above) and make housing stock less affordable.
We recommend that there is a presumption against extensions, and consider 30% far too generous. We recommend that Permitted Development Rights should be removed within Dartmoor National Park.
We recommend that ‘such as inter-war bungalows’ should be added to the final sentence.
We recommend that ‘removal of a dilapidated dwelling’ should be deleted. Many historic and architecturally non-listed assets have been swept away on Dartmoor because they have been labelled as ‘dilapidated’ or as an ‘eyesore’ or ‘disfigurement’. Buildings that have been abandoned or poorly maintained are some of those most at risk from emotive superficial assessment of their appearance, yet most can be fully restored and remain as historic markers within the Dartmoor landscape.
We recommend that ‘woodland’ should be added here as an acceptable business (see comment p.55, above, re forestry).
p.80 – the illustration on this page does not seem relevant to the topic.
We welcome this policy but with heartfelt irony, given the aggressive and negative treatment of Steward Community Woodland.
We recommend that there should be a section on provision of Public Toilets which are essential for the well-being of visitors and residents alike.
We recommend that the route of the Tavistock–Okehampton railway should be protected from prejudicial development, and that much fuller analysis should be given to the provision of rail transport in, or close to, the National Park (see the item on p.2 of The Western Morning News of 23 January 2019 detailing the remarkable increase in use of local railways since 2001). We recommend that there should be positive statements about the potential reopening of the Teign Valley Railway and the Newton Abbot–Moretonhampstead line, and that the Local Plan should endorse reopening of the Tavistock–Okehampton line as a priority.
We welcome the Strategy as set out on p.119, paragraph 6.1.5 (p. 120) and Strategic Policy 6.1 (1) New or Extended Minerals Operations, especially 2. and 3. (p.121).
We recommend that ‘removal of plant and other infrastructure’ should be rewritten to take account of the cultural significance of mineral working of any period. We recommend that the policy should include a statement, ‘Where possible, redundant plant and infrastructure should be left in situ as historic markers for the future’.
We welcome this section.
‘Barn Park’ should read ‘Holne Road’.
We welcome these maps, especially the inclusion of Listed Buildings.
We recommend that the Conservation Area should be extended northwards to include all the buildings within the ‘Settlement Boundary’ alongside and west of the Two Bridges Road (i.e. including Bellever Close for its distinctive Cornish Unit houses and ‘The Cottage’, which is the northernmost building on the west side of the Two Bridges Road which was erected as a bakehouse for the War Prison in 1809/10), and should be further extended to include New London on the Two Bridges road as a rare example (1871) of industrial housing, and Ockery Barn and the ruins of Ockery Cottage at Oakery Bridge (just off the map) which were two of Princetown’s earliest buildings (the barn dates to 1808 and the cottage to 1805).
We recommend that there should be a map for Lydford and also maps for all 18 villages and hamlets shown on Map 1.1. (p.21) as well as the additional settlements we recommend under 1.4.6 (p.21), above.
The heading of Column 1 should read ‘Policies superseded’ not ‘Policies superceded’.
Tom Greeves, Chairman, 29 January 2019
Posted in Responses/Comments on Wednesday 2nd January 2019 at 9:09pm
The following are the key responses to the questions asked, made by Dr Tom Greeves on behalf of the Dartmoor Society in December 2018:
8. What do you think does not work overall about the system and might be changed?
The system is flawed due to the lack of democracy in that none of the members of Dartmoor National Park Authority (and other NPs) are directly elected by the residents of the national park – see the more detailed response to Question 15. Any NP or AONB is only as good as the staff and members. More high quality specialists are needed, with regular training and debate for all employees and members of the Authority. For example, it is extraordinary that there is no trained and qualified historian working for Dartmoor National Park.
9. What views do you have about the role National Parks and AONBs play in nature conservation and biodiversity?
Theoretically they play a very important role. However, Dartmoor National Park staff do not challenge the dominance of Natural England and so have little influence. They also seem easily led by fashionable concepts such as rewilding or peatland ‘restoration’ and do not take the lead themselves in coming up with new ideas.
Could they do more to enhance our wildlife and support the recovery of our natural habitats?
Yes, by encouraging sustainable use of woodlands, and by resisting the policies of Natural England and fashionable concepts of rewilding and rewetting of peatlands without evidence-based reasoning. The staff of NPs and AONBs should be the best qualified to shape new policies and thinking, but need more training and debate.
10. What views do you have about the role National Parks and AONBs play in shaping landscape and beauty, or protecting cultural heritage?
The concept of ‘natural beauty’ needs to be challenged as the beauty of our National Parks and AONBs is very much a product of cultural activity over millennia. The protection of cultural heritage on Dartmoor has been poor – in the past twenty-five years, many archaeological features on open moorland have been smothered in vegetation largely due to the erroneous polices of Natural England (and English Nature). The protection of historic buildings is very patchy and there is a serious lack of understanding of the importance of 19th and 20th century buildings as evidence of the continuum of human presence and activity.
11. What views do you have about the role National Parks and AONBs play in working with farmers and land managers and how might this change as the current system of farm payments is reformed?
On Dartmoor, much more respect needs to paid to the Dartmoor Commoners’ Council (created by the Dartmoor Commons Act 1985) as its members embody centuries of experience of good livestock husbandry.
12. What views do you have about the role National Parks and AONBs play in supporting and managing access and recreation?
At the moment there is too much support for large-scale recreational events (e.g. cycling and running) which can have a damaging effect in many ways.
13. What views do you have about the way National Park and AONB authorities affect people who live and work in their areas? Are they properly supporting them and what could be done differently?
There is surprisingly little support for the livelihoods of local people, especially those that have innovative and environmentally-friendly ideas. Recently the National Park has been aggressively hostile towards a community woodland settlement (Steward Wood) and to a sustainable woodland project (Hillyfield). Both these should have been singled out for praise by the NP as exemplars of alternative ways of managing land in environmentally gentle ways.
14. What views do you have on the role National Park and AONB authorities play on housing and transport in their areas?
There are insufficiently strong policies for genuinely affordable housing.
15. What views do you have on the way they are governed individually at the moment? Is it effective or does it need to change, if so, how?
The government of national parks needs radical overhaul. There is a fundamental democratic deficit in that 33,500 residents of Dartmoor National Park (and other NPs) are not able to vote for candidates in local elections who have put themselves forward to represent them on the National Park Authority. This is an extraordinary ‘black hole’ in the British democratic process as the current National Park Authority makes potentially life-changing decisions on a monthly basis affecting the environment and livelihoods of these residents. And yet none of the members of the Authority has been chosen specifically by the residents to represent them on the NP Authority.
16. What views do you have on whether they work collectively at the moment, for instance to share goals, encourage interest and involvement by the public and other organisations?
There has consistently been a poor level of engagement of NP staff or of members of the Authority with the local community – this is fundamentally a problem of the ‘culture’ of national parks, i.e. that a national park must fundamentally be ‘a good thing’ and so staff and members tend to cocoon themselves into a state of cosy mediocrity, and sometimes a sense of superiority, without true engagement with local people (at parish meetings or community events). As an example, in our experience, NP staff or members have very, very rarely attended the numerous events which the Dartmoor Society has organised over twenty years and which have been open to the general public.
19. What views do you have on the process of designation – which means the way boundaries are defined and changed?
The boundaries of designated areas are a concern. On Dartmoor, for example, it is bizarre that the key towns of Okehampton, Tavistock and Bovey Tracey are excluded from the National Park as they are essential to the economic and social well-being of those who live within the present boundary. Logically, based on culture, geology, etc, the Dartmoor region should extend westwards to the River Tamar, which would be a natural boundary.
20. What views do you have on whether areas should be given new designations? For instance, the creation of new National Parks or AONBs, or new types of designations for marine areas, urban landscapes or those near built-up areas.
We would not support the creation of any new national parks unless the issue of the democratic deficit was resolved. In any area, high quality information about the natural and cultural environment, shared with local communities, should be the basis of good decision-making. Designations should not, in theory, be necessary, as communities would take pride in what was known about their place and so would instinctively safeguard it. We recommend the creation of Ecocultural Zones for all open moorland and Access Land – see the more detailed response to Question 23.
22. Do you think the terms currently used are the right ones? Would you suggest an alternative title for AONBs, for instance and if so what?
The term Area of Outstanding Natural Beauty is misleading and woolly as a concept. These are clearly cultural landscapes shaped by millennia of human interaction with the land and its ecosystems. Area of Outstanding Cultural Landscape would be more accurate as a title.
23. The review has been asked to consider how designated landscapes work with other designations such as National Trails, Sites of Special Scientific Interest (SSSIs), Special Areas of Conservation (SACs), National Nature Reserves (NNRs) and Special Protected Areas (SPAs). Do you have any thoughts on how these relationships work and whether they could be improved?
A plethora of designations is confusing for the general public. Within national parks, we have concluded that, on open moorland, the current legal designations of Site of Special Scientific Interest and Scheduled Monument, and the informal designations of Premier Archaeological Landscapes, are no longer fit for purpose and have failed to deliver good management of either the natural or the cultural environment. The SSSIs were created from 1952, for nature conservation reasons alone, and have dominated decision-making on open moorland. At that time there was no understanding of the extent of the cultural landscape of Dartmoor which we now recognise to be one of the finest in the world in terms of extent, chronological range, diversity, state of preservation and ease of access. It contains messages for 8000 years of human relationship with the land. The dominance of SSSIs has created an imbalance between Nature and Culture. We therefore need a new legal designation of Ecocultural Zone for open moorland and access land, with nature and culture given equal weight. This would transform thinking and management decision-making.
24. Do you have any other points you would like to make that are not covered above?
There should be overt support for small-scale local use of local resources of stone, wood and minerals, plus micro-hydro energy schemes and any other low-impact environmentally-friendly projects. There should be much more emphasis on high quality research. National Park HQs should be research ‘hubs’ with an unrivalled ‘library’ resource, freely available to the general public, of information relating to all aspects of the cultural and natural environment of the national park.
Posted in Responses/Comments on Sunday 21st August 2016 at 9:26pm
Dr Kevin Bishop
Chief Executive
Dartmoor National Park Authority
Parke
Haytor Road
Bovey Tracey
Devon
TQ13 9JQ
20 August 2016
Dear Kevin,
Hillyfield Plantation & Tom’s Brake, Harbourneford – Application 0259/15
I am aware that in June 2015 DNPA refused planning permission for a new wood drying barn and a store for tools and machinery at Hillyfield Plantation, and in January 2016 served enforcement notices on several structures, and that a planning inquiry is scheduled for March 2017 to consider the owners’ three appeals (3140928, 3146596, 3146597) against these actions.
Having had an opportunity to visit the site and to discuss its management with the owners and others, I am persuaded that Hillyfield is a fine example of how woodland on the fringes of Dartmoor can be sustainably managed, with community benefit, in the 21st century. Rather than causing any harm to Dartmoor, visually or otherwise, it is a significant asset of which the National Park should be proud.
Therefore I am now writing on behalf of the Dartmoor Society to respectfully ask Dartmoor National Park Authority to rescind its refusal of planning permission and its enforcement notices, and to withdraw from the planning inquiry. These would be noble and wise gestures, which would be widely welcomed. Such action would also enhance the reputation of the Park Authority and would save the expenditure of considerable sums of public money and other resources.
I look forward to hearing from you soon.
Yours sincerely,
Tom Greeves, Chairman, The Dartmoor Society
Posted in Responses/Comments on Sunday 21st August 2016 at 9:22pm
Dr Kevin Bishop
Chief Executive
Dartmoor National Park Authority
Parke
Haytor Road
Bovey Tracey
Devon
TQ13 9JQ
20 August 2016
Dear Kevin,
Proposed Distillery in Princetown threatens historic 1920s Electricity Generating Station Building designed by Richardson & Gill
I understand that there has recently been some public consultation about the creation of a proposed whisky distillery in Princetown. I was not able to attend this, but understand that the proposed distillery would require the demolition of the Electricity Generating Station at SX 58877348, immediately adjoining the west side of the carpark. This building has recently been used as the Princetown Smithy/Forge.
I would like to draw your attention to the fact that the Electricity Generating Station is an important part of Princetown’s historic fabric, and that everything should be done to prevent its loss. Not only was it the first provider of electricity for Princetown, but was designed in 1923 by Richardson & Gill, the Duchy architects who were nationally among the best-known architectural firms of the inter-war period. On its north side, there is a fascinating coloured plaque specially designed in London for the building. A good summary history of the building, based mainly on Duchy records, by Ted Luscombe, was published by the South Western Electricity Historical Society in 2002, titled ‘Princetown Electricity Supply’ (Supplement 1 to Histelec News No.21).
Princetown has lost many important historic buildings (the Railway Station, the Town Hall which was also designed by Richardson & Gill, the Imperial Hotel, Bolt’s Stores, Morwenna House and others) and it would be tragic if this building was also demolished. For a discussion of these losses and of the importance of Princetown’s built fabric see my Presidential Address: ‘Dartmoor & the Displacement of Culture: Analysis & Remedy’ in Transactions of the Devonshire Association, 147 (2015), pp20-24.
So far as I am aware the building is not listed and falls just outside the Conservation Area, but this reflects lack of information and understanding at the time of designations, and should not diminish a sense of its importance.
I have also written to Tom Stratton of the Duchy of Cornwall. The Dartmoor Society would be most grateful if you could use your good offices 1) to draw the attention of your Historic Buildings Officer to the importance of the building 2) to advise the promoters of the distillery to amend their plans in order to preserve the building, and 3) to take steps to ensure the long-term safeguarding of the building by finding an appropriate use for it.
Yours sincerely,
Tom Greeves, Chairman, The Dartmoor Society
Planning inspector Paul Freer during a site inspection
Posted in Responses/Comments on Sunday 21st August 2016 at 9:19pm
Society progresses through innovation – in science, in arts, in rights for humans and creatures, and in how to care for the environment. But not it seems on Dartmoor: Last week a planning inspector made a decision which could lead to the eviction of 12 adults and nine children from their low-impact homes in Steward Community Woodland. This was established sixteen years ago, near Moretonhampstead.
The community, having twice been given temporary permission to continue living in the woodland, after appeals, applied to Dartmoor National Park Authority for approval of permanent residence in the woodland, which they own. The unelected Authority refused in 2015, and issued an enforcement notice. The community appealed, and the inspector, Paul Freer, has dismissed that appeal.
His report reveals a misinformed logic, a shallow understanding of landscape, and an attitude of mind that should have no place in the modern world, and certainly not within a national park.
He considers both the existing and proposed development unacceptably harms, or would harm, ‘the character and appearance of Dartmoor National Park’ and ‘the purposes of National Park designation’. Mr Freer considers the lack of a continuous tree canopy ‘erodes the character of the woodland’; permanent occupation would cause ‘irreversible erosion of the canopy cover’, despite ‘minimal’ visual impact.
Yet, for centuries, the deciduous woodlands of Dartmoor were full of human activity – by charcoal burners, bark strippers (for tanning), moss gatherers, miners, and others, whose clearings were an integral part of Dartmoor’s ancient story of woodland management. The 32 acres of Steward Community Woodland once included a farmstead – Stewardwood – and comprise numerous ancient enclosures. Field names reveal varied historic land-use: coppicing, orchards, a pond, a barn, even a possible mill, besides woodland.
The inspector’s report is perhaps most flawed in respect of cultural heritage. Since the Environment Act of 1995 all national parks have a primary purpose to conserve and enhance ‘natural beauty, wildlife and cultural heritage’. Mr Freer mentions ‘natural beauty’, but omits any discussion of historic or contemporary cultural heritage. Yet, in 16 years the woodland residents have added an important and cultural distinctiveness to the Wray valley.
The inspector considers the adjoining sewage works, rifle range and the A382 to be less damaging than the ‘residential enclave’ in the woodland, which he says is ‘urbanising’, ‘not well integrated into the landscape’, and not of ‘high quality design’.
Although he agrees that the community ‘does broadly achieve its stated aims ’, with ‘81% of requirements met from the land’, he argues that this level of self-sufficiency could not be maintained or controlled by planning conditions.
He acknowledges considerable local support but patronisingly dismisses it by balancing it against the ‘national resource’ of a national park and the ‘understanding and enjoyment of its special qualities’ – as if local people have no appreciation of this, nor play any part in it.
Mr Freer blithely states that he has been provided with no evidence to indicate that it would not be possible for residents to find accommodation in the local area within a year. He does admit that their rights under the European Convention of Human Rights and the Human Rights Act 1998 would be interfered with, but considers that to be justified on account of the more important ‘opportunities for others to enjoy and understand the special qualities of the national park’.
A national park that cannot accommodate and celebrate the community woodland clearly needs reform. The residents’ lifestyle is unusual, but is refreshing and stimulating. They have demonstrated a remarkable commitment, through winter rains and storms, to a way of life very different from most of us. They are deeply integrated with the very supportive local community. Their gentle impact on the land, philosophy and brave experiment should be celebrated, and presented as a leading example of how some of us might live in the future, supported by an innovative and flexible park authority which, since July 2013, has even introduced a policy for ‘low impact residential development in the open countryside’ .
The park was created in 1951 when the world population was one-third of what it is now and that of England was only 41.2 million compared to its current 54.5 million. Roger Deakin, who knew Dartmoor, wrote in Wildwood of a woodland community, that it was ‘a practical demonstration that there is another way to live, on terms of greater intimacy with the woods and land – slower, more deliberate and benign: a quiet assertion of greenwood values.’ The dismissal of their appeal is a denial of what Dartmoor could and should be, at a time of environmental concern.
Tom Greeves is chairman of the Dartmoor Society, cultural environmentalist and, as President of the Devonshire Association 2015-2016, author of Dartmoor & the Displacement of Culture: Analysis and Remedy.
Posted in Responses/Comments on Thursday 6th August 2015 at 10:54pm
Dear All Members and Friends of Yennadon Quarry,
We would like to draw your attention to the letter shown below generated by our Chairman Dr Tom Greeves in support of Yennadon Quarry’s plans to obtain planning permission to complete a proposed, modest expansion. The planning application is logged under number 0348/15 and if like us you wish to support Yennadon Quarry please feel free to generate a letter of support yourselves.
From a historical point of view there is more information regarding Yennadon Quarry’s plans etc in a previous Dartmoor Society Newsletter, Number 51, dated October 2014 which has a picture of the Quarry on the front cover. Also at the time, Tom wrote on behalf of the Dartmoor Society to the Western Morning News outlining his disappointment at the DNPA recommending refusal of the Quarry’s previous planning application itemised (number 0667/13) which was also for a modest expansion programme. This letter was featured on pages 9–11 in our Dartmoor Society Newsletter Number 51 and there was also a write up regarding a very successful Dartmoor Society walk incorporating Yennadon Quarry on Wednesday 11th June 2014 led by Liz Miall on pages 17–19 of the same Newsletter.
Looking at Yennadon Quarry’s current situation your valued support for this extremely essential, but also very discreet local enterprise is greatly appreciated.
Many thanks.
Tanya Welch
Honorary Secretary, The Dartmoor Society
Posted in Responses/Comments on Thursday 6th August 2015 at 10:47pm
James Aven
Dartmoor National Park Authority
Parke
Haytor Road
Bovey Tracey
Devon
TQ13 9JQ
4 August 2015
Dear James,
Applcn 0348/15 – Yennadon Quarry
I am writing on behalf of the Dartmoor Society which has a membership of some 450 persons. For seventeen years the Society has been an independent voice for those who find Dartmoor a source of livelihood or inspiration.
We fully support this application by Yennadon Quarry for modest expansion to allow fulfilment of its current planning permission to 2025. The application reaches to the heart of understanding and awareness of the cultural history and landscape of Dartmoor, and of sustainability and the wise use of resources.
Yennadon is the last active stone quarry working on moorland Dartmoor, out of scores that once existed. As such, it is a cultural icon and living heritage link to the previous generations of quarrymen and their families, who have shaped what is one of the finest cultural landscapes in the world.
Amazingly, this small-scale enterprise supports a workforce of twenty-seven. It provides stone for a wide area of west Devon and beyond, and is maintaining the historical value of Dartmoor which has always shared its resources (minerals, water, livestock etc) beyond the limits of Dartmoor itself. Its scale is entirely appropriate to modern Dartmoor and adds character to the Dartmoor landscape.
The proposed expansion poses no significant threat to archaeology, ecology or the wider landscape and, once the quarry has ceased working (2025), it will soon become an intriguing site, sitting quietly within a moorland setting. After abandonment, we advise that foundations of any structures within the quarry should be left undisturbed, for the education and interest of future generations.
This quarry is exactly the type of small-scale locally distinctive enterprise, making wise use of Dartmoor’s resources, that deserves widespread encouragement. We urge Dartmoor National Park Authority to approve this application.
Yours sincerely,
Tom Greeves MA PhD
Chairman, The Dartmoor Society
Posted in Responses/Comments on Wednesday 15th July 2015 at 8:06am
The Dartmoor Society are delighted to receive a long awaited reply from James Cross of Natural England to our Chairman’s original letter dated 27th May 2015 on the subject of “Ponies on Dartmoor and grazing calendars for agri-environment Schemes”. Sincere thanks to John Holmes for his assistance in obtaining James’s response.
James Cross’s letter is shown in its entirety below.
Natural England
Natural England Mail Hub
Block B, Whittington Road
Worcester
WR5 2LQ
7 July 2015
Dear Dr. Greeves
Ponies on Dartmoor and grazing calendars for agri-environment schemes
Thank you for your letter to James Cross of 27th May: he has asked me to reply on Natural England’s behalf. We have received a lot of correspondence on this issue since the item in the Western Morning News and it is encouraging that people care so much about ponies. Natural England owns a small herd of Dartmoor ponies that does an important job in helping us to manage our East Dartmoor Woods and Heaths National Nature Reserve, as well as adding greatly to the enjoyment of our visitors. We are quite clear that for many reasons the ponies should be a valued part of the landscape of Dartmoor long into the future.
Alongside the Dartmoor National Park Authority, we work with the Dartmoor Pony Society, the Friends of the Dartmoor Hill Pony, the Dartmoor Hill Pony Association, The Dartmoor Pony Heritage Trust, the commoners’ associations and other interested parties to help ensure that is the case. Primarily this has been by developing management agreements which provide financial support to farmers and commoners to help them with their careful management of their livestock and Dartmoor’s landscape.
Grazing by both cattle and ponies can be beneficial for nature on Dartmoor: the overall stocking level and timing are the most important factors in helping nature to thrive. It is the commoners’ associations and individual agreement holders who make the detailed decisions on the precise mix on ponies, sheep and cattle on the moor at any one time. However, I can assure you that there is no plan at all for Natural England to remove ponies from grazing calendars and replace them with other types of animals.
Understanding is the key to implementing effective grazing regimes so additional information is always welcome. Perhaps The Dartmoor Society could share its research through the Pony Action Group chaired by the National Park Authority? We are working with them and the Commoners Council to scope out what more research would be most useful to all interested parties. Our lead on this topic is Naomi Oakley naomi.oakley@naturalengland.org.uk.
Yours sincerely
John Holmes
Area Manager
Devon, Cornwall & Isles of Scilly Team,
Natural England
Posted in Responses/Comments on Sunday 19th May 2013 at 9:46pm
The following is the text of the 10-minute presentation which Dr Tom Greeves gave at the SW Uplands Federation Conference on 19 October 2012.
In the past two decades two core policies of Natural England and DEFRA have been applied to Dartmoor commons which are misplaced, damaging and potentially disastrous in cultural terms – the policies of destocking the commons and rewetting the mires.
The destocking seems to derive essentially from a belief that heather moorland is the optimum vegetation for the Dartmoor commons and that its decline in the post-war period is due to ‘overgrazing’. Neither tenet holds good. What is so special about heather? There certainly was more heather on Dartmoor in the mid-20th century but it was not always so. And did overgrazing really exist? – it did in some very particular areas where poaching occurred but actually the grazing pressure of the 1970s and 1980s was hugely beneficial in terms of the ‘public good’, enabling walkers to roam freely, farmers to tend and gather stock easily, and, of special importance, it revealed a suite of archaeological remains not seen before in the 20th century.
The huge levels of destocking required under so-called environmental schemes (up to around 80% in some instances) in the last two decades have not resulted in the reappearance of heather. Instead we have unpalatable long grasses, and gorse, which impedes access, endangers those gathering stock and obscures one of the finest archaeological landscapes in the world, thus preventing research and analysis.
The second core policy, that of rewetting the mires, has been carried on in various guises since 2007, and is based on a fundamental misunderstanding of the Dartmoor blanket bog. The bog is old – 8,000 years or so – and inevitably where it has built up to a depth of 2m or more, on slopes of a certain gradient, pieces will occasionally ‘calve’ off like an iceberg from a glacier. If a plateau bog (like Winneys Down 1 and 2 or Flat Tor Pan), pools will form on its flat wet surface. These will eventually revegetate quite naturally as evidenced from the Flow Country of Scotland (4000 square km of blanket bog). The core tenet of this project is that the bog is eroding. Of course it is – all land surfaces erode – but what has not been demonstrated is that this erosion is in any way significant or different to what has happened before. We have eyewitness descriptions going back nearly 200 years (disgracefully not researched by any of the partners in the project) that describe the bogs as they are today – nothing significant has changed. To justify work of the cost and scale now in progress, such significant change should long ago have been demonstrated, based on long-term observation. There are no such data, and there is no crisis that needs dealing with.
Despite five years of so-called pilot schemes, we still have no results in the public domain. The first two schemes at Amicombe and Blackabrook Down were on the sites of commercial peat digging of the 19th century and essentially involved blocking ditches despite these being ecological niches being gently filled by natural means. More recently, with money which supposedly Ofwat has allowed South West Water to raise from its water rates, attention has been turned to previously undisturbed plateau bogs with peat up to 6m deep and still growing. No proof of significant or unexpected erosion has been presented. Astonishingly, machines have been allowed to access these remote areas (Winneys Down 2 is more than 3 miles from the nearest road) to dig blocks of undisturbed peat and vegetation and then use them to create dams behind which water pools as a potential hazard, while forming unsightly tracks etc where no such thing existed before. Yet close at hand in each of these areas are plenty of examples of natural revegetation which has not been observed and monitored.
Three cultures are pertinent here:
The so-called partnership is not one of equals. The dominant culture of Natural England and DEFRA has shown itself to be coercive and arrogant, threatening graziers who hesitate to sign up to HLS or support the Mires Project, or who counter demands to reduce stocking levels. Whose knowledge counts?
The body which has the prime statutory duty (under the Dartmoor Commons Act 1985) to look after the husbandry and grazing of the commons is the Commoners Council. All other parties should be supporting this role and subsidiary to it, but able to offer advice and money where appropriate. Restocking of the moorland is essential in order to create the overarching public good of a dominant grassland sward, but one full of subtle variety. The present damaging rewetting programme involving machinery and disturbance should be abandoned immediately. The project should shift radically to one of observation, monitoring and benign research, if need be over a long timescale, recognising that the 12,500 hectares of Dartmoor blanket bog are like an old friend – wrinkled, characterful but wise. Only thus will the core culture of Dartmoor hillfarming be maintained and encouraged.
Tom Greeves illustrated his presentation with several quotes, which are given below:
1. Heather – ‘a symbolic plant in much ‘conservation specialist’ thinking...Yet many ecologists will point to heather-dominated stands of vegetation as among the least species rich’(Prof. Ian Mercer, Dartmoor – A Statement of its Time (2009), 112-3)
2. Livestock numbers on Dartmoor Commons:
c. AD 1200-1500 – a minimum of 10,000 cattle summer grazing on the Forest, plus 10,000 on surrounding commons = 20,000 cattle + 100,000 sheep (Harold Fox, Dartmoor’s Alluring Uplands (Univ of Exeter Press, 2012, 91)
1808 – 14,000 sheep on ‘commons belonging to the parish of Widecombe...besides the usual proportion of horned cattle’ (Charles Vancouver)
October 1942 – estimate by Head Ranger (Endacott) of stock levels on military range: 10,000 sheep, 200-300 cattle (in winter), 2,000-3,000 cattle (in summer), 1500 ponies (National Archives)
November 1942 – estimated numbers of stock on West Quarter : 2,000 bullocks, 10,000 sheep, 1000 ponies (National Archives)
1963 – 2,000-6,000 ponies; 50,000 sheep (Dartmoor Commoners/RSPCA/Horse & Ponies Protection Association)
Pre- Cross Compliance of mid-1990s – approx. 20,000 animals (Andy Guy of Rural Development Service of DEFRA, speaking at 9th Dartmoor Society Debate, 2006, ‘’Designer Wilderness? What Future for Dartmoor’s Vegetation?’)
2006 – fewer than 10,000 animals - since introduction of ESAs in 1994 (Andy Guy, idem).
3. Vegetation:‘The grass is getting so long we’re losing all the birds – the skylarks are going and there are no lapwings any more – and people can’t walk in some places’ (Farmer Donna Penwill quoted in Western Morning News, 12 October 2012).
4. Blanket bog: ‘the East Dart...proceeds down the valley, augmenting considerably as it drains the hill on the west side, which is one immense peat-bog, broken into small banks or hillocks, the intervals being entirely occupied with a swamp of black peat. These several morasses are indeed worthy of inspection, being the origin of numerous brooks and rivers, although little known or visited by the explorers of Dartmoor wonders.’ (May 1830 – Sophie Dixon, A Journal of Ten Days Excursion on the Western and Northern Borders of Dartmoor pp 25-6).
5. Blanket bog: ‘The ground, which for many feet deep is nothing but black peat of a soapy consistency, is rent into chasms running in every direction, and the surface is thus divided into small islands, as it were, covered with a coarse grass...This boggy land...stretches for several miles...and cannot fail to impress him who seeks its solitudes. There is a grandeur about these wild portions of the forest, where nature still reigns with undisputed sway...’ (1888 – William Crossing, Amid Devonia’s Alps or Wanderings & Adventures on Dartmoor pp 127-8).
6. Rewetting: ‘The areas [of Dartmoor] which are currently being wetted do not benefit reservoirs directly’ (Alison Butts, South West Water, email to Elisabeth Greeves, 27 February 2012) .
7. Comments by Dartmoor Commoners’ Council Members on the effects of Destocking/Rewetting, and signing up to ESA/HLS agreements:
‘We have destroyed our living’ - ‘We are indigenous people being pushed and pushed and pushed’ - ‘We don’t trust them [Natural England] any more’ - ‘We are slowly losing our place here’
But compare: ‘I don’t want to alienate people who send us whacking great cheques’.
8. Dartmoor Commoners’ Council: ‘Under the Dartmoor Commons Act 1985 the Dartmoor Commoners’ Council governs the exercise of common rights, animal husbandry and vegetation management on the commons’ (Dartmoor National Park Management Plan 2007-2012, p.31).
Posted in Responses/Comments on Monday 25th June 2012 at 9:57pm
14 May 2012
Dear Tom,
Thank you for your letter dated 29 April 2012 addressed to Lorna Brown, sorry it has taken a while to respond.
Seminar – I note your interest in the proposed seminar, this will be a chance to share the research and monitoring programme for the Project. As requested I will keep you informed of progress and we would welcome your attendance.
Flat Tor Pan – we note your views on this but Lorna clearly spelt out our position in her letter of 12 April.
Erosion – At this stage I have nothing further to add to the information previously supplied. It is the view of our own staff, experts in the field, Natural England, the Environment Agency and South West Water that parts of Dartmoor’s peatlands are eroding. The aims of the project are three fold; to restore blanket bog; to improve water quality and to protect carbon. As we have clearly spelt out in the past this is a pilot project, to consider feasibility and impact on the above three aims. The seminar may provide an opportunity for you to hear how this is progressing and speak to Dr Lunt and other specialists.
Analytical Work – It is the view of experts, our own staff and project partners such as Environment Agency, Natural England and South West Water that natural colonisation of bare peat will not take place where there is running water and erosion. Through the project we are monitoring the effects of reducing running water on colonisation.
Thank you for your continued interest in the project. I have tried to provide as much information as I can but there is very little to add given the amount of information provided in previous correspondence.
Yours sincerely,
Ally Kohler
Director of Conservation and Communities
Posted in Responses/Comments on Tuesday 28th February 2012 at 12:03am
To: Sue Goodfellow
From: Christopher Walledge
Date: 13 February 2012
I have been asked to advise in writing regarding the proposed fencing works on Broad Down relating to hydrological monitoring equipment which is to be deployed as part of the monitoring process for the Dartmoor Mires Project.
The proposed fencing of part of the commons engages the provisions of the Commons Act 2006 and the Dartmoor Commons Act 1985.
Section 38 of the Commons Act 2006 enacts a general prohibition on any restricted works on common land without the consent of the Secretary of State. Fencing (permanent or temporary) is one of the restricted works:
- the erection of fencing;
- the construction of buildings and other structures;
- the digging of ditches and trenches and the building of embankments.
This makes it clear that the prior consent of the Secretary of State is required for the erection of fencing if it will have the effect of preventing or impeding access to, or over any common land.
However, there is an exception within section 38 which is relevant to the proposed fencing at Broad Down. Section 38(6) provides that the general prohibition in s.38(1) shall not apply to:
This means that if there is a specific statutory power to erect fencing on the commons, it will override the general prohibition in the Commons Act 2006.
Section 10 of the Dartmoor Commons Act 1985 makes provision concerning public access to the commons. Section 10(4) empowers the National Park Authority to regulate or prohibit for such period as may be reasonably necessary, access by all or any part of the public to any part of the commons, provided it is for one of three purposes specified in the subsection. The second exception is as follows:
The 1985 Act also provides that the Authority may fence and enclose parts of the commons for as long as may appear necessary for the attainment of the purposes of the regulation or prohibition of access in pursuit of the aim set out in (b)(i) above.
The Dartmoor Mires Project is primarily concerned with the restoration and conservation of the commons. The hydrological survey equipment is required to monitor the restoration work and evaluate its success. The fencing is a direct consequence of the deployment of the hydrological equipment. Given the intended use of the equipment and fencing, the Dartmoor Commons Act permits the Authority to deploy the equipment and fence it without the need for consent from the Secretary of State.
It should be noted that the power in section 10(4) is subject to a number of restrictions. Section 10(8) preserves the right of the owner of the commons (or any person acting on behalf of the owner) have access to every part of the commons at any time. Section 10(9) requires the Authority to serve notice by newspaper advertisement of the regulation/prohibition of access by the public, its intended duration and the reasons which it has made and inviting written representations within 28 days after the date of publication of the notice. The Authority is also required to consider all such representations so made before making its determination, save in case of an emergency.
A notice was place in the Western Morning News setting out details of the proposed restriction of public access on common land at Broad Down and inviting representations by 10 February 2012.
The Dartmoor Commoners Council and Dartmoor Forest Commoners Association were individually consulted, as required by section 10(4)(b) of the 1985 Act. The Central Council of Physical Recreation were also consulted, as required by section 10(9) of the 1985 Act. In the event, three responses were received: from the Open Spaces Society, the Dartmoor Society and a Mr Paul Rendell.
The Authority has given public notice of its intention to rely on powers conferred under s.10 of the Dartmoor Commons Act 1985. It has also consulted with the Dartmoor Commoners Council, the Dartmoor Forest Commoners Association and the Central Council of Physical Recreation as required.
No objection has been received to the need, location, extent, type or duration of the proposed fencing.
Some questions have been raised whether the proposed works constitute an appropriate use of the Dartmoor Commons Act 1985, but no case law or legal opinion has been produced to show that the Authority is not entitled to rely on the powers under s.10 of the 1985 Act in conjunction with the exemption under s.38(6) of the Commons Act 2006.
In all the circumstances, it is my opinion that the Authority has engaged in an appropriate public consultation process which has not resulted in any significant objection in law or principle to the proposed works.
I do not believe that there is any legal impediment in proceeding with the erection of fencing and siting of hydrological monitoring equipment on Broad Down as proposed.
Posted in Responses/Comments on Monday 20th February 2012 at 11:02pm
The Dartmoor Society has put together a slideshow of images and issues surrounding the Dartmoor Mires Project which you can watch below or on our YouTube channel.
Posted in Responses/Comments on Friday 10th February 2012 at 8:39am
Dartmoor Mires Project – Proposed Restriction of Public Access on Common Land at Broad Down – Dartmoor Commons Act 1985 Section 10(4)
Representations of The Dartmoor Society
1. The Dartmoor Society (hereafter ‘The Society’) was established in 1998 to be ‘an independent voice and a forum for debate for those who find Dartmoor a source of livelihood or inspiration’. It is a registered charity (no. 1111066) with broadly educational aims, and has more than 500 members.
2. The Society has consistently questioned the purpose, efficacy and management of the Mires Project – see Newsletters 34 (February 2009) pp 5-7; 35 (June 2009), p.13; 37 (February 2010) pp 3-5; 38 (June 2010) p.3; 42 (October 2011), pp. 27-32. We have also held a relevant public Debate (September 2008), two relevant public Research Lectures (in 2007 by Dr Ralph Fyfe and in 2010 by Lauren Parry), and had site visits to both Blackabrook and Winneys Down. The Society also argued (in a letter to Dr Kevin Bishop dated 30 April 2010) that the works at each site required consent from the Secretary of State under the Commons Act 2006, and that there should be a Public Inquiry.
3. The Society welcomes this opportunity to make representations as it is the first time since work began on Dartmoor mires in 2007 (at Amicombe Hill) that the public have been given an opportunity to comment. However, it is surprising that, two years into the Dartmoor Mires Project (2010–2015), this proposal is only now being made.
4. The Society has always argued that research and scientific monitoring (re hydrology, etc) should be part of any ‘rewetting’ project, especially in advance of any physical work on site creating dams etc. Regrettably and, in our opinion, inexcusably, no hydrological monitoring has yet happened at any of the ‘pilot’ sites (since 2007) nor in connection with the specific Dartmoor Mires Project which is already 40% through its time schedule of 5 years (2010–2015), and the results of any other monitoring (erosion/ photographic/vegetation/birds/invertebrates/historic environment/peat cutting), if it has taken place, are not in the public domain.
5. The proposal before us has an element of advance monitoring, which we welcome in principle, and we accept that scientific equipment for advance monitoring will need to be fenced.
6. However, we do not support the proposed works due to take place after the advance monitoring phase, at ‘Broad Down’ itself, for the following reasons:
6.1. The location is wrongly named ‘Broad Down’ being approximately one mile north-west of Broad Down. The location of the project is properly known as Flat Tor Pan and should be referred to by that name. That the managers of the project call it ‘Broad Down’ does not reassure us regarding their knowledge of Dartmoor.
6.2. The Society is concerned that, on information it has received, there has been no plenary session of the Dartmoor Commoners’ Council to assess and discuss the proposal at length, and so members of that Council have been denied an opportunity to discuss it collectively, which is surely the very purpose of that Council.
6.3. The Society believes that application for the works (monitoring and other) should be made to the Secretary of State under Section 38 of the Commons Act 2006 rather than by using Section 10 (4) of the Dartmoor Commons Act 1985. The latter has a key criterion of ‘protection and restoration of the natural beauty of the commons’, which the fence will not in itself do, and Section 10(4) is intended to keep people off small areas of eroded land for short periods, not the nine years asked for in this instance. The proposed works at ‘Broad Down’, after initial monitoring, include the disturbance of ground and the creation of scores of peat dams or embankments (some with timber) over some 10 hectares of ground [Source: Fig. 2 in Arnott, S. (2011) Dartmoor Mires Project Hydrological Monitoring Plan; email from Frances Cooper, Dartmoor Mires Project Officer 18 Jan 2012]. Among restricted works which require consent under Section 38 of the Commons Act are ‘fencing…ditches, trenches, embankments’ and ‘works which might have the effect of preventing or impeding access to or over the land’, and the Society believes the proposed works fall under these categories. In a letter to Dr Tom Greeves dated 4 May 2010 Dr Kevin Bishop, Chief Executive of Dartmoor National Park, argued that the reason Section 38 (Commons Act 2006) consent was not then being sought on rewetting projects was that the works ‘do not have the effect of preventing, or impeding, access to, or over, the land’. This is clearly not the case with the proposed fence. Therefore, on their own criteria, Dartmoor National Park Authority should now apply under Section 38 of the Commons Act 2006.
6.4. Furthermore, the Society is concerned that a decision on the representations for the proposed works is, at the moment, in the hands of Dartmoor National Park Authority which has a financial interest (£1.1 million) in the project and so cannot be considered an unbiased and impartial party. The Secretary of State should therefore be the arbiter, through use of Section 38 of the Commons Act 2006.
6.5. Three so-called ‘pilot’ schemes have already been initiated on Dartmoor since 2007 – Amicombe Hill, Blackabrook and Winneys Down. Despite it now being almost five years since the start of the first of them, there is no detailed information in the public domain giving results and assessments of these projects. The Society would argue that no further project should be initiated and that there should be no further expenditure of money and public resources until the results of the previous ‘pilot’ schemes have been properly and rigorously assessed, and data published with accurate maps and plans.
6.6. Fundamentally, the Society is not persuaded that the need for rewetting has been proven, nor that any evidence has been presented to show that there is any recent erosion of the Dartmoor peat which is different to that which has occurred naturally over several hundred if not thousand years. We challenge the claim of South West Water that the works associated with the Dartmoor Mires Project at Winneys Down and elsewhere will cause cleaner run-off into reservoirs (and thus save them money otherwise spent on treating ‘turbid and discoloured water’), as none of the sites drains into a reservoir from which water is abstracted, and we also challenge their claim that ‘downstream flooding risks’ will be reduced (including, it was implied, in Torquay, to which no Dartmoor rivers flow).
6.7. The work already undertaken at Winneys Down is a major cause for concern, especially relating to the tracks made by vehicles, the interference with a previously undisturbed and healthy bog, potential hazards to livestock and walkers due to the depth of the ponds (1–2 ft deep with soft peat at the bottom), and the unstable nature of those dams/embankments which have become waterlogged (the ponds fill with water then overflow), besides the lack of any hydrological monitoring etc.
6.8. Graziers claim they have lost grazing ground at Blackabrook due to the water-filled dams/embankments, and that the ponds are a potentially fatal hazard to livestock. One grazier lost a sheep in 2010 and another lost a calf in 2011.
6.9. No mention is made of the aircraft crash site at Flat Tor Pan which is of historic/archaeological interest, with debris from a Sea Vixen from Yeovilton which crashed on 31 May 1965, the pilots ejecting safely. The site is in the vicinity of a pond (which may have been created by the impact of the crash) in the heart of the project area, and should not be disturbed. The pond itself deserves study and monitoring.
6.10. The Society is concerned about the increasing costs of the monitoring proposals which were initially said to be £90,000 (DNPA website Briefing Note June 2011), but which Dr Sean Arnott has assessed as an average of £102,280 (Arnott, 2011, op.cit., p.26).
7. The Society therefore requests that there should be a full Public Inquiry into the Dartmoor Mires Project before any further ‘pilot’ project or monitoring is started, or money spent, as we believe there are many grounds for concern and issues of public interest regarding the justification, purpose, efficacy, costs, consultation process and management of the current project and previous related works, all of which deserve a full hearing and public scrutiny by a neutral party or parties. We consider that any delay and costs that might be caused or incurred by a Public Inquiry will be beneficial in the long-term as the matter reaches to the heart of hill farming on Dartmoor and the proper management of the commons, and is of major interest for graziers, scientists, land managers and the general public.
Yours faithfully,
Tom Greeves MA, PhD
Chairman, The Dartmoor Society
Copies to:
Posted in Responses/Comments on Sunday 22nd January 2012 at 9:55pm
We had chosen St Swithun’s day for this expedition to high Dartmoor, and the weather forecast was doubtful as ten members gathered in the carpark at Fernworthy Reservoir. Our guides were Frances Cooper (Mires Project Officer of DNPA), Andy Guy from Natural England, and Peter Challis (DNPA guide required for ‘health and safety’!). Several of us were surprised to see two ugly, urbanising and unwelcome notices and a ‘Pay & Display’ machine installed by South West Lakes Trust in March 2011. While a donation ‘cairn’ might not have been inappropriate, these intrusions seemed quite wrong in such a location, and could be a most undesirable precedent for other Dartmoor reservoirs. The reservoir was significantly ‘drawn down’ due to the dry year experienced so far.
Combined in four cars we drove to the top end of the reservoir and then through a locked gate onto the forestry tracks which took us to the Moorgate nearest the Grey Wethers stone circles. A few spits of drizzle alerted us to put on wet weather gear at this point. From here there was an easy walk to Sittaford Tor past the impressive circles. Crossing a stile over a newtake wall, we saw a lovely herd of belted Galloways, belonging to Mr Patrick Coaker of Bittleford. We headed south-westwards to a point between the head of the Maish Hill Brook and Winneys Down Brook, at approx. SX 6230 8200. Here at a height of about 1700 ft OD (517m) we were at the centre of one of the deepest peat bogs on Dartmoor, with peat 5.5–6.7m (18–22 ft) deep and proven to be 8,000 years old. Dr Ralph Fyfe of Plymouth University has conducted this work, using ground penetrating radar, coring and radiocarbon dates.
A steady light rain had begun by this time. The surface of the ground was damp and distinctly spongy, and vibrated if you stood still and another person walked by. Sedges (including White Beak Sedge – Rhynchospora alba – which is an indicator of ‘actively forming bog), cotton grass, sphagnum species, sundew and several flowering plants were in abundance – spiders and other creatures could be observed. It was a beautifully atmospheric spot. The ground contained some low ‘hummocks and hollows’ which indicates a healthy bog (we were shown similar features on our Exmoor visit with Dr David Smith in 2010).
Frances Cooper explained what was intended here in what she described as a ‘pilot project’. A grant of £1.1m from South West Water is funding a 5-year project which began in 2010. This includes the salaries of Frances and a specialist peat archaeologist from Ireland, Nicola Rohan, who is to start a 3-year stint soon. The project is a partnership between DNPA (who lead the project), South West Water, the Environment Agency, the Duchy of Cornwall and the Commoners Council. Other interested parties who are involved in the process include Ministry of Defence, Forest of Dartmoor Commoners Association, Royal Society for the Protection of Birds, English Heritage and the Dartmoor Access Forum. It was pointed out that the Dartmoor Society was not included, but we were told that ‘all Dartmoor Society issues are represented’!
The practical work on Winneys Down will consume about 25% of the budget (c. £250,000). This is due to start in September/October 2011 and consists of five weeks of work intended to prevent the erosion of the precious bog, undertaken by contractors working with a 7–8 tonne ultra low pressure vehicle, moving blocks of peat to dam shallow channels (including already vegetated ‘islands’ within the channels) in order to encourage growth of sphagnum and other plants on bare peat. Scepticism about the use of such machines on such ground, and concern about the damage it might do, was expressed by an experienced digger driver among our group, not least because the vehicle will be required to track back to a temporary ‘depot’ to pick up fuel.
Unlike at Blackabrook and Amicombe, no timber is to be used in the construction of dams, and the aim here is not the rewetting of the peat but the ‘restoration’ of the vegetation of the bog where there are shallow open channels. The view was expressed by Society members that these channels might be an entirely ‘natural’ process within the bog and a phenomenon that is likely to have been associated with peat bogs since their origins several millennia ago, but Andy Guy claimed that the bog had been damaged by overgrazing and by fire and pointed out exposed peat to support his arguments – but no real evidence was presented. We were shown the edge of a wildfire that had burnt in April – this is now completely revegetated with new growth and looked very healthy, though the official view is that it was damaging.
We were then taken to some eroding peat gullies at the head of the little ‘combe’ that runs down to join the start of Sandy Hole Pass on the East Dart at SX 6215 8150. These gullies are clearly draining from the main bog and define the edge of the bog itself. There is no intention to attempt to block these gullies but, instead, shallow channels on a very slight gradient above the gullies will be given similar treatment to those on the main body of the bog itself – i.e. they will be blocked with peat in the hope that vegetation will take hold. The theory goes that if these ‘feeder channels’ can be revegetated then erosion further downslope can be reduced. Our group noticed that several of these channels were being revegetated with cotton grass (Eriophorum) by natural processes without human interference.
We were told that no hydrological monitoring will take place on Winneys Down.
Despite more or less continuous light rain we were not enveloped in fog and could see something of the surrounding landscape. A late lunch was taken in the shelter of Sittaford Tor and a return to the carpark was made by 3pm.
In addition to SWW funding Natural England has put in £250,000 to cover archaeological/historical work and LiDAR surveys. Frances Cooper told us that the historic environment was ‘hugely important’. A further £1.2m will be available annually under Higher Level Stewardship from 2012 to support graziers who have ‘lears’ (i.e. traditional grazing areas) for their cattle and sheep on or near the blanket bog.
A significant amount of research has been carried out and is planned. Dr Phil Newman has made a study of the peat industry which is titled Domestic and Industrial Peat-Cutting on North-western Dartmoor, Devonshire: an Archaeological and Historical Investigation. We were told that this will be made available on the Mires Project website.
A major hydrological monitoring and restoration project is to be undertaken on 24 ha of bog at Flat Tor Pan at approx. SX 613812 (bizarrely, this is to be called ‘Broad Down’ by the Mires Project as the managers seem ignorant of the name Flat Tor Pan (although it was recorded by Brian le Messurier in his article ‘The Phillpotts Peat Passes of Northern Dartmoor – a pioneer survey’, Trans. Devon. Assoc.,97, 1965, 161–170), and the managers were not happy with an alternative suggestion of Wildbanks Marsh). The Environment Agency and the University of Exeter will be conducting this work, for a minimum of 5 years and, hopefully, nine. The ‘restoration’ is due to take place in the autumn of 2013. The monitoring equipment will be within a fenced area and this will require permission from the Secretary of State as works on common land (this is welcome and may be at least partly due to pressure of the Dartmoor Society).
More detailed work on the profile of the peat by Ground Penetrating Radar is also planned in a 1km × 4km transect across Winneys Down and beyond. Surveys of breeding birds and invertebrates are also to be undertaken.
We were all most grateful to Frances Cooper, Andy Guy and Peter Challis for giving us their time, and for answering the many questions put to them.
We welcome the new emphasis on historical and other research and data gathering, which is what the Dartmoor Society has always argued was needed if the project was to have any credibility. We are also pleased that no timber is to be used in the forthcoming ‘restoration’ works, and that permission from the Secretary of State is to be sought for the fencing at Flat Tor Pan (‘Broad Down’). So it would seem that the concerns of the Dartmoor Society have, to some extent, been heeded. However, we still have considerable reservations about the practical so-called restoration. This is to be carried out at Winneys Down without any previous monitoring of the channels over a number of years to observe their condition. We need to know the processes by which the observed natural revegetation takes place – might it not, for example, be linked to the accumulation of dry molinia grasses blown into the channels to a significant depth in winter? Without this data and monitoring, the claim that the bog is eroding is unproven, and a lot of public money and carbon is to be expended on human interference which is likely to result in new vegetation growth but without being based on rigorous investigation. We are also concerned about the ‘spin’ put on the project as a whole. South West Water (who have invented the term ‘Upstream Thinking’) quite untruthfully claimed on their website that the project would stop flash floods in the South Hams and Torbay area, and that it will reduce run-off and provide clean water which will save them money – despite the fact that none of the project areas drain into reservoirs or indeed Torbay. Claims are also made by Natural England and others that the blanket bog is drying out and eroding. We want to see real data (e.g. comparative aerial photographs) supporting these assertions, but none has yet been produced. Claims about overgrazing and the damage caused by fires seems equally unsupported by hard evidence. We also require reports in the public domain giving us the results of the previous ‘pilot projects’ on Amicombe Hill and Blackabrook Down’.
From my own experience of walking Dartmoor over more than half a century, it would seem that the very wet ‘blanket peat’, on the plateau at Winneys Down is relatively uncommon and certainly different in character (in its vegetation communities, hydrology etc) to that found on the slopes and tops of the high hills of the north moor (e.g. Cut Hill), and it would be good to have a specialist opinion about this.
Sophie Dixon in 1830, described the ground in the vicinity of the headwaters of the East Dart, referring to ‘one immense peat-bog, broken into small banks or hillocks, the intervals being entirely occupied with a swamp of black peat’ (A Journal of Ten Days Excursion on the Western and Northern Borders of Dartmoor, Plymouth, 1830, p.25) . It would seem that the character of Dartmoor peat has not changed radically in nearly two hundred years and, presumably, much longer. The managers of the Mires Project need to provide hard evidence in support of any claims to the contrary.
Tom Greeves, with help from Barry and Tanya Welch.
Posted in Responses/Comments on Sunday 22nd January 2012 at 9:39pm
In the Introduction to this document of 193 pages, paragraph 1.1.2 states ‘The DMD provides the more detailed policies that are needed to supplement the strategic policies in the Core Strategy Development Plan Document’.
In our Newsletter 35, June 2009 we noted that ‘It is slightly disconcerting to be told that somehow the Core Strategy and Management Plan (to which very significant resources have been applied) are not sufficient in themselves to guide the decision-makers, but we must welcome the principle of more detailed policies being developed in some areas of management.’
It would now seem that our cautious optimism was misplaced as, apart from its inclusion of Settlement Maps, there is little to distinguish this document from the Core Strategy. The consequence is that we now have a second layer of policies, not clearly distinguishable from each other, as well as a third layer of policies in the DNPA Management Plan. This is totally unnecessary bureaucracy (imposed by Government) and a patently obvious waste of resources when one policy document should suffice for all three.
In May 2009 we sent very specific comments to DNPA on some of the sixty-nine Topics included for discussion in the draft DMD document, plus comment on other issues. Our comments are published in our Newsletter 36, October 2009, 7–10.
It is disappointing that scrutiny of the present document reveals that most of the Dartmoor Society’s comments of May 2009 have been ignored, without any opportunity for discussion. There are two significant exceptions where our views have been supported, at least partially – a) DMD 28 Replacement Dwellings in the countryside – this gives greater control over replacement dwellings. b) DMD 31 Low Impact dwellings in the Countryside - this is the first DNPA policy to recognise the potential benefit of ‘alternative’ forms of dwelling, and has relevance to the Steward Wood Community whom we have consistently supported in the face of aggressive opposition from DNPA.
The Settlement Maps, which in principle are a valuable addition, are actually disappointingly bland. Some show nothing at all apart from the layout of the settlement. This is a missed opportunity – they should show, for example, all those buildings which are statutorily listed, the location of all known archaeological features recorded on the HER, and the presence of open space and gardens, plus significant natural features such as trees covered by Tree Preservation Orders. Some simple colour coding would enable such information to be clearly presented. Without such information, the parish community and the lay person is little the wiser about what is known and protected in their place.
Many of the proposed policies are stating the obvious, given that national parks are ‘confirmed by Government as having the highest status of protection in relation to landscape and scenic beauty’ (para 2.1.4). Somewhat worryingly, in the same paragraph ‘conservation of wildlife and the cultural heritage’ appear to be given a lesser status as ‘also important considerations’.
The more specific policies (DMD17–DMD31) are the most useful ones.
The successful outcome of all policies depends on the dissemination of sound information and the constant training of both officers and members of DNPA.
It is high time that DNPA recognised and stated that the current management of the Dartmoor Training Area is not ‘in conflict with national park purposes’ and indeed makes a positive contribution to many of them.
Core Strategic Aim – Landscape Evolution – the phrase ‘archaeological qualities’ is a strange one. Perhaps ‘tangible presence of the past’ would be better.
2.7.2 ‘drivers of future landscape change’ – there should be a statement in this paragraph about the negative influence of increasing population pressure and the increasing consumption of resources.
2.8.4 Moor and Heath of Conservation Importance – the ‘conservation importance’ of Moor and Heath needs to be defined/expressed more fully – ‘natural beauty’ is not a sufficient description to justify conservation alone and there needs to be inclusion of the cultural landscape.
2.8.6 Orchards – the fact that only 76ha of orchards survive (780 separate orchards existed within DNP in 1960) should be a matter of major concern and there should be a strong policy to actively encourage their renovation/recreation.
There is much mention of ‘heritage assets’ (‘not designated but which have heritage value and which are therefore a material planning consideration’) arising out of the Government PPS5 – Planning for the Historic Environment. While the concept has some merit, DNPA has for many years been notoriously bad at giving non-designated features of archaeological or historic interest due consideration when giving advice on, or taking, development control decisions. Policies DMD (iv), DMD9, DMD10 and DMD12 and paras 2.10.2.–2.10.6 and 2.10.9 have a hollow ring to them in view of the recent fate of historic buildings within the Conservation Area of Princetown, of Yellowmeade Farm, of a granite barn at Two Bridges Hotel, and of Mount Pleasant Farm, Murchington, besides numerous other sites. It is good to have a policy in place, but it will have no effect unless officers and members are constantly trained and informed about new data and ideas relating to the historic environment.
In particular, there needs to be a policy statement specifically relating to 20th century buildings and their importance in architectural, historical and social terms, as they are the buildings often most at risk through a misplaced assumption that somehow they are of lesser importance than older buildings.
Para 2.10.6 – mention of ‘Boulton & Paul’ needs expanding such as ‘Boulton & Paul bungalows of the early 20th century’.
2.10.16, line 1 – add ‘or heritage asset’ after ‘listed building’ as many heritage assets are not listed.
This is not a clearly written section, and contains repetition. There needs to be a clearer statement about the extent and time-frame of archaeology on Dartmoor, including mention of 20th century features such as industrial and wartime sites. Is the correct terminology ‘Scheduled Monument’ or ’Scheduled Ancient Monument’? The former seems increasingly used (and is used in the Ancient Monuments & Archaeological Areas Act 1979), so why is the term ‘ancient monument’ used in the text?
We remain critical of the concept of PALs (Premier Archaeological Landscapes), claimed to be of ‘international importance’ (2.11.2), as an inappropriate (and ineffective) management tool of open moorland or moorland newtakes because they create a hierarchy of value which implies that non-PAL areas are somehow less important. Para 2.11.3 reveals a very muddled and unsatisfactory state of affairs. What is needed is a strong statement giving an overall designation for all open moorland, moorland newtakes and access land as ‘culturally significant’ with a presumption against any development.
Para 2.11.4 ‘The skeleton of the present day enclosed landscape is of some antiquity and contains many archaeological sites’ is a very odd sentence, and needs rewriting. What exactly is meant by ‘skeleton’ and ‘some antiquity’ in this context?
Figure 2 – Strategic Nature Areas - this map and its key are curious, and needs careful checking. Much Woodland seems to be missing from it, and much of what is shown as ‘Neutral Grassland’ is surely Woodland? The heart sinks at yet another designation ‘Strategic Nature Area’.
2.14.4, line 27 Renewable energy – add ‘and archaeological’ after ‘ecological’.
DMD21 – Telecommunications Development. The final paragraph of this policy states that a ‘condition will be applied requiring the removal of all structures and the reinstatement of the site if the development becomes redundant’. This should be deleted as such a policy is in conflict with good archaeological management practice of leaving at least the foundations of any abandoned structure. It is specially important in relation to modern structures which are easily labelled as ‘eyesores’ once abandoned and yet have an important story to tell, and are silent historic witnesses once abandoned. A good example of management has recently been implemented by Sibelco UK relating to modern clayworking structures south of Cadover Bridge (see ‘In Focus’ in Dartmoor Online, Autumn 2011 – www.dartmooronline.co.uk).
If such a condition had been applied to Dartmoor in the past we would have no archaeology left at all!
This must be considered one of the most important issues, and more data is needed.
2.20.6 Housing provision – There needs to be a Table showing the numbers of dwellings built and permissions given in the period 1996–2011 (this corresponds to the Devon County Structure Plan period for which there was a ‘target’ of 800 new dwellings within that 15-year period). The ‘target’ figure has been greatly exceeded and there needs to be a statement about this in the present document. The ‘indicative level’ of 50 units per year 2006-2026 also needs context, including the fact that in the two-year period 2006-2008 permissions for 247 new dwellings had already been given (see Newsletter 36 p.9).
2.20.11 Definition of ‘local people’ – Consideration should be given to including ‘essential service providers’ under the definition of ‘local people’.
2.20.19 ‘larger cohorts’ is a strange expression.
2.20.22 Domestic gardens – These should not be defined as ‘previously developed land’ but should be redefined as ‘open space of wildlife, cultural, social and visual importance’.
2.20.25 and DMD25 – Extensions – There should be a policy presumption against extensions as they diminish the stock of smaller dwellings. Permitted Development Rights should be removed within Dartmoor National Park.
2.20.28 and DMD28 – Replacement dwellings in the countryside – We welcome the stronger protective statements here, including the removal of Permitted Development Rights, but it would be helpful to reinforce them by stressing the importance of many 20th century buildings which are often seen as candidates for replacement.
2.20.31 and DMD31 – low impact dwellings in the countryside – We welcome this new approach to low impact dwellings but the phrase about restoration of the site to its former condition when occupation ceases (para 2.20.31, lines 16-18) should be deleted for the reasons stated above (DMD21).
We feel there should be a policy about the desirability of having public conveniences in heavily-used recreational areas e.g. Cadover Bridge.
There is no evidence to support the specific date of 1285. We suggest deletion of ‘since 1285’.
3.2.6 Stannary Town – The prosperity of the tin industry in Ashburton actually peaked in the first half of the 16th century, not the end of the 15th century.
3.4.8 Stannary Town – In 1305 Chagford was confirmed as a coinage/stannary town. It had existed as a coinage town before then.
There are extensive ancient tinworks in Biera Wood which is shown on the east of the map p.97 – this should be mentioned in addition to Bellacouch Meadow (which is not shown on the map, and should be).
3.5.3 There is no evidence that Horrabridge was established in the 14th century – it will have existed long before then as a settlement. Mention should be made of the important evidence of medieval and later tinworking at Fillace Park, linked to Furzehill mine, and to Wheal Franco which was one of the most important copper mines on west Dartmoor.
3.5.4 ‘Inappropriate development’ – DNPA needs to recognise that this development was approved by DNPA!
More than any other Dartmoor settlement, Princetown has suffered a considerable loss of historic fabric in recent years through demolition and neglect of key 19th century and Edwardian buildings within the Conservation Area! The most notable recent casualties have been Morwenna/Stoneycliffe House and Bolts Stores, but include the Town Hall (designed by Richardson & Gill) and many other structures.
Thus the statement that the Duchy Square Centre for Creativity has ‘improved the character and appearance of the village centre’ rings very hollowly, as does much of para 3.7.5, especially the claim that the Conservation Area is ‘an important asset in its tourist appeal’, as well as the claim that there has been ‘conservation and enhancement of heritage assets’ and that (3.7.7) Princetown’s ‘architecture tells an important story’. The reality has been the exact opposite, with the destruction of much of what should have been recognised as a unique settlement of the 19th and early 20th century.
It is vitally important that the present document recognises that errors have been made and that there are still key buildings at risk e.g. Grosvenor House, Prison Officers’ Social Club etc.
The importance of Plymouth/Drake’s Leat and the Devonport Leat needs to be mentioned, as well as the route of the Plymouth & Dartmoor Tramway.
3.9.1 Airfield – Correction needed – this is sited on Roborough Down and was known as Harrowbeer Aerodrome.
3.16.3 Bridge – There was an ancient bridge here – the earliest reference known to it is in 1568 (a tinworking deed).
3.19.2 Correction needed: the quarry is on the north-east side of the village not the south-east side as stated.
Mention should be made of the lime quarries.
Mention should be made of the important restoration of several of the houses in the village in the late 1930s by Capt. C.W. Quelch (see Shears, R.T. (1968) Conservation of Devon Cottages). It is surprising that Ilsington does not have a Conservation Area.
There should be a statement about the integrity and attractiveness of the 19th century buildings of Lydford. The site of ancient Lydford Mill should be included within the Conservation Area, as well as the road junction and field containing the prehistoric barrow (‘tumulus’)/gallows site/windmill site, WNW of the war memorial.
3.27.4 There never was a ‘stannary courthouse’ here, only the gaol. However, the Forest Court was held in the Castle. The Castle itself deserves mention!
The Conservation Area should include ‘Croftner’ at the junction of Bal Lane with the A386.
3.30.4 Deserted farmsteads – these should be shown on the map. Warrens is known as a farm site but where are Bowdens and Palmers?
3.31.1 - mention should be made of Mount Pleasant Farm having origins around AD 1400.
Mention should be made of its strong mining tradition, and of the rare presence of a working farm (Chubb Farm) in the centre of the village.
What has happened to its proposed Conservation Area?
The whole of North Hall should be within the Conservation Area.
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
Posted in Responses/Comments on Wednesday 2nd June 2010 at 8:29pm
Tom Greeves
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.
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).
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.
4.1. 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.
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.
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