The natural aspect - Epping Forest and Rock Creek Park


Earlier this year, I came across an extraordinary report written in 1865 by Frank Law Olmsted, the landscape architect who had designed the layout of Central Park in New York. It was a preliminary plan for Yosemite Valley, written after the Valley had been granted to the State of California by the Federal Government in 1864 "upon the express conditions that the premises shall be held for public use, resort, and recreation; shall be inalienable for all time…" (1)

The novelty of the legislative grant of Yosemite was that it provided for publicly owned land to be reserved for strictly non-utilitarian purposes, thus establishing a principle that would be central in the future of America’s National Park system. Olmsted, who had become one of the first Commissioners of Yosemite Valley, ran with that principle in his report, but he also brilliantly described its natural, scenic beauty, and how important it was for ordinary people to experience it (2):
“If we analyze the operation of scenes of beauty upon the mind, and consider the intimate relation of the mind upon the nervous system and the whole physical economy, the action and reaction which constantly occurs between bodily and mental conditions, the reinvigoration which results from such scenes is readily comprehended. Few persons can see such scenery as that of the Yosemite and not be impressed by it in some slight degree”

As I wrote when I first discovered the report (3) Olmsted would appear to have been at the forefront of thinking about the importance of contact with wild nature for human well-being, the effect of natural scenery on human perception, and the moral responsibility of democratic governments to preserve regions of extraordinary natural beauty for the benefit of the whole people - a democratisation of wild nature (2):
“The main duty with which the Commissioners should be charged should be to give every advantage practicable to the mass of the people to benefit by that which is peculiar to this ground and which has caused Congress to treat it differently from other parts of the public domain. This peculiarity consists wholly in its natural scenery”

Olmsted proposed to manage Yosemite by prohibiting the grazing and logging that threatened the vegetation of the area. He also provided a costed breakdown of ideas for managing the valley for human access with minimal harm to the natural environment – a simple circuit road and a few paths in the valley would provide access without being intrusive (2):
“The first point to be kept in mind then is the preservation and maintenance as exactly as is possible of the natural scenery; the restriction, that is to say, within the narrowest limits consistent with the necessary accommodation of visitors, of all artificial constructions and the prevention of all constructions markedly inharmonious with the scenery or which would unnecessarily obscure, distort or detract from the dignity of the scenery”

It was in his description of the impressive character of the Sierra Nevada mountains that Olmsted put forward the notion that the experience of Yosemite should not only consist of spectacular views of monumental rock pinnacles, but that it should be a continuous one –a succession of scenes where the peaks were part of compositions in which the smaller elements that were in closer proximity also played a crucial part (2):
“It is not, however, in its grandeur or in its forest beauty that the attraction of this intermediate region consists, so much as in the more secluded charms of some of its glens formed by mountain torrents fed from the snow banks of the higher Sierras. These have worn deep and picturesque channels in the granite rocks, and in the moist shadows of their recesses grow tender plants of rare and peculiar loveliness. The broad parachute-like leaves of the peltate saxifrage, delicate ferns, soft mosses, and the most brilliant lichens abound, and in following up the ravines, cabinet pictures open at every turn, which, while composed of materials mainly new to the artist, constantly recall the most valued sketches of Calame in the Alps and Apennines”

To come across the reference to the works of Swiss painter Calame was a delightful surprise, since a few months before reading Olmsted’s report, I had gone to the Forests, Rocks, Torrents exhibition of 19th century Norwegian and Swiss landscape paintings at the National Gallery in London. I saw for myself the order and precision that Calame brought to his paintings of the Aare, the largest river in Switzerland, which he sketched in the uninhabited uplands of the Bernese Oberland (4). Fast-moving water (torrents) was a central theme in Calame’s work, and his scenes of that upland river show the forces of nature strongly acting within the landscape, as Olmsted observed they did in Yosemite.

Olmsted had been impressed with how the people in certain cantons of Switzerland had provided facilities and a welcome to travellers to “share with them the enjoyment of the natural scenery of their mountains”. He knew from his travels elsewhere in Europe that this was not always the case. He noted that wealthy elites had always found a way to escape to their own private preserves, providing places of recreation for themselves, such as the “large and as luxurious” rural retreats of the “aristocracy of Europe”. He was unflattering about Britain (2):
“There are in the islands of Great Britain and Ireland more than one thousand private parks and notable grounds devoted to luxury and recreation………… The enjoyment of the choicest natural scenes in the country and the means of recreation connected with them is thus a monopoly, in a very peculiar manner, of a very few very rich people. The great mass of society, including those to whom it would be of the greatest benefit, is excluded from it. In the nature of the case private parks can never be used by the mass of the people in any country nor by any considerable number even of the rich, except by the favor of a few, and in dependence on them”

Olmsted read the Report to his fellow Commissioners at a meeting in the Yosemite Valley on August 9, 1865. Unfortunately, it was met with indifference and some hostility (vested interests were threatened) and it was not implemented by the Commissioners. Olmsted returned East shortly afterwards, but kept his vision alive by having a letter published in New York’s Saturday Evening Post on June 18, 1868, entitled The Great American Park of the Yosemite, and which contained a section of his report (5). His call for restrictions on activities in the Valley would see vindication in later legislation from 1890 that established Yosemite as "reserved forest lands”, excluding settlement and putting the valley under the control of the Secretary of the Interior John W. Noble, who was empowered by the legislation to make rules and regulations as to its care and management (6):
“Such regulations shall provide for the preservation from injury of all timber, mineral deposits, natural curiosities, or wonders within said reservation, and their retention in their natural condition”

I was so taken with Olmsted’s report that I challenged colleagues on whether they could identify the authorship of such sentiment for public accessibility to natural scenery. No one recognised it as originating from America. However, one name given to me was John Ruskin, the art critic and patron in Victorian England, but who was also a prominent thinker on social justice and public service. It would be Ruskin who would inspire Octavia Hill, one of the founders of the National Trust in 1894, to want access to nature for those trapped by poverty in towns (7). Another given to me was Robert Hunter, also a co-founder of the National Trust, but it was for his earlier involvement as the honorary solicitor for the Commons, Open Spaces and Footpaths Preservation Society, and his opposition to the enclosure of Epping Forest, a Royal hunting Forest.

It would seem that this action to prevent enclosure of Epping Forest is regarded as a significant event in the nineteenth century, in securing public access to open space. At first thought, it would be a fascinating juxtaposition to the grant of Yosemite and Olmsted’s report on the management of the valley. However, the more I have looked in to it, the more it seems to reveal divergent aims and entirely different outcomes.

The Royal Forest of Epping

Epping Forest was the last remnant of the Royal Forest of Essex that extended over most of the county in the twelfth century (8). It was populated with fallow deer, a non-native Eurasian species originating from the Middle East that may first have been introduced to Britain by the Romans, but it was the Normans who cemented its presence as a free-living feral species. A Royal Forest did not necessarily mean woodland as it does today– it was an area of land, not always in the ownership of the Crown, where Forest Laws operated to protect deer belonging to the king. Royal Forests usually covered a large tract of common-land over which the deer were found to live. The commons were different from others, since they were grazed by the king's deer as well as livestock, even though land within them was bought, inherited, and given just like any other land. As with commons, Forests were not fenced, their boundaries marked by landscape features such as hills, rivers, and boundary stones. They thus relied on the strong force of habit of fallow deer as a species to remain within the Forest area (8).

At the beginning of the fourteenth century, Essex Forest had shrunk to an area that covered only the south west of the county, known as the Forest of Waltham, and which included what we know now as Epping Forest and Hainault Forest. The Forest became a favourite hunting ground for the Tudor and Stuart monarchs, both for recreation and for the venison it could provide for their tables. As late as the 17th century Waltham Forest was described in the Exchequer Bills of Charles I as “alwaies especiallie and above all theire other forests, prized and esteemed by the Kings Maiestie and his said noble progenito” (9)

By the 1720s, Epping Forest had a clear identity - the name Epping Forest is first recorded in 1662 – and its area was only a little larger than it is now (8). It had a long, narrow shape running NS, and with many roads and tracks crossing the Forest. The perimeter of the Forest was surrounded by the commoners' houses, densely in places, which faced on to the Forest and backed on to their own private fields.

Royal Forests, like the larger commons, did have some areas of woodland as well as areas of scattered trees, the more open areas being known as wood-pasture since they involved both grazing and trees. Few timber trees grew in the Forest, trees that could be used in construction, either because grazing prevented the growth of saplings, or because the commoners lopped them and made them into pollards. As with all situations where livestock graze, the more trees there are, the less extensive will be the pasture, as its growth is constrained by shade. On the other hand, the more animals grazing the pasture, the more difficult it becomes for the trees to regenerate.

In Epping Forest this conflict between grazing and trees was stabilized by having distinct grassy plains (Wanstead Flats, Chingford, Fairmeads, Hatch, Honeylane, Whitehall, Copley, Deershelter and Sunshine Plains) with few or no trees, on which much of the grazing took place, and by pollarding the trees. There is no evidence to indicate that a cycle operated between plains and trees, as has been suggested as the ''natural'' pattern of the Forest (8). Pollarding (lopping) was favoured over coppicing as it avoided the new growth being grazed off at ground level. It could also have benefited the livestock because grass would spring up in the greater light between the trees after pollarding. However, so many accounts of the Forest refer to the high density of pollards that it is doubtful if much useful grass reappeared because of lopping.

Royal Forests such as Epping were a complex example of multiple land-use, based on the rights of three different users (8): the Crown in keeping and hunting deer; the lords of manors and other landowners, in making use of their ownership of the soil through grazing the grass and harvesting what timber there was; and the commoners, having a variety of rights to grazing and taking wood from pollarding. Deer and livestock could thus roam over the whole of the Forest, but timber and wood could only be cut on the territory of a landowner's or commoner's particular manor. The significance of this cross-manor grazing in Epping Forest will become clear later.

The enclosures of commons of the 18th Century had hardly touched Epping Forest, but the destruction of neighbouring Hainault Forest in 1851 put Epping under threat. As well as owning the Forestal Rights at Hainault, the Crown also owned the manorial rights and the soil (10). In 1817 the Commission of Woods and Forests applied for an Act of Parliament to enclose part of Hainault Forest for the Crown, to do away with commoners right in the forest, and disafforest the whole Forest (removing the Royal Forest status). That Act failed, but the Commissioners did not give up their intention to realise the value of the land, and an Act was passed in 1851 for the Disafforestation of Hainault Forest, its open lands were for the most part enclosed and converted to arable land and building land. A contract was made with a manufacturer of steam ploughs, who dragged anchors through the soil, uprooting the trees. It took only six weeks to clear 3,000 acres

The Commissioners of the Office of Woods and Forests then proceeded to offer the Forestal Rights of Epping Forest for sale to the various lords of manors, thus removing that land from the jurisdiction of Forest Laws. It was a tempting offer, which emboldened action by the lords of the manors, as the Commissioners implied that their purchase by the manorial lords would give the absolute right to enclose, as a first step towards the sale or development of the land. The extension of railways had increased the demand for, and the value of, land in the suburbs like Epping. The Crown sold the Forestal Rights over large portions of the Forest (11). In 1850 the Forest comprised almost exactly 6,000 acres. Soon, enclosures of large blocks, often of several hundred acres in extent, were carried out by the manorial lords. Concern at the enclosures led to a Select Committee of the House of Commons being appointed, which reported in June 1863 that the Forest was being destroyed, and recommended that the Forestal Rights of the Crown should be asserted where they had not been sold, to prevent further enclosure (10, 12). Two years later another Select Committee was appointed to enquire into all the open spaces round London (10, 13, 14). The committee heard the view of the lords of the manors that providing they could reach a compensatory agreement with their commoners, then they had the right to enclose. This committee repeated the recommendation of the previous one, that the Forestal Rights of the Crown should be enforced. During the ensuing years, half of the area of Epping Forest was surrounded by fences, the commoners rights in several of the manors had either been compensated or surrendered, large tracts had been cultivated, much of it had changed hands, and many houses built (11).

The defence against enclosure of Epping Forest

The Commons, Open Spaces and Footpaths Preservation Society had been set up in 1865 by George John Shaw-Lefevre with an aim to resist the rising tide of illegal encroachment of common land, and thus purportedly preserve public access to open spaces (15). The year 1871 would see a number of steps in defence against enclosure of Epping Forest, inspired by the Society. Thus William Cowper-Temple, the MP for South Hampshire and a member of the Society, brought a resolution to the House of Commons on 28 April 1871 “that measures be adopted …. for preserving as an open space accessible to Her Majesty's subjects for purposes of health and recreation, those parts of Epping Forest which have not been enclosed with the assent of the Crown or by legal authority” (16). It was not supported, but it did give rise to the passage in the next session of the Epping Forest Act 1871, which appointed a Royal Commission - the Epping Forest Commission - to establish the boundaries, encroachments, and enclosures of Epping Forest; to investigate manorial claims to and commoner's rights on Forest land; and to resolve a Scheme for disafforesting the Forest, and the preservation and management of its waste lands. Evidence was submitted to the Commission by the lords of the manors and those claiming commoner's rights, including the City of London Corporation as it owned a property in the Forest and thus had grazing rights (10, 17, 18).

In August 1871, the Corporation of the City of London instigated a Chancery suit (Commissioners of Sewers v Glasse and others) in the public interest on behalf of themselves and all other owners and occupiers in Epping Forest against the lords of the manors. The intention of this suit was to prevent further enclosures and to obtain a declaration that all owners and occupiers were entitled to rights of common over the waste lands. Robert Hunter acted with the corporation's solicitor, Sir Thomas Nelson, in the conduct of the legal proceedings. (10) It was contended on behalf of the lords of manors that each manor was separate, and that its commoners had no rights over the remainder of the Forest. A commoner was someone who owns or occupies at least half an acre of land in one of the four Forest parishes (19). On behalf of the Corporation, it was asserted that there never were such boundaries to access between manors, and that the commoners had always enjoyed the right of "inter-commonage" as it was called, for their cattle to wander all over the Forest (10).

After three years, the Master of the Rolls, Sir George Jessel, delivered a judgment on the 24th November 1874 that decided in favour of the Corporation, that the rights of common of pasture extended throughout the Forest. This overturned the legality of the enclosures that had taken place up to that point, but also made it impossible for any new enclosures based on manors. The City of London Corporation then set about securing as much of the land as they could, purchasing the wastelands in the manors of Chingford, Loughton, Waltham Holy Cross, Higham Hills, Sewardstone, Cann Hall, Chingford Earls and manorial rights in Queen Elizabeth's Hunting Lodge (17, 19). In effect, the judgment blighted the land, and so it was not surprising that the Corporation was able to buy up those manors. What the corporation then did with that open space would be the subject of further legislation on the Forest.

Robert Hunter made a study of the law affecting common rights. He would later give his ideas on the better preservation of open space in a paper presented at the Annual Congress of the National Association for the Promotion of Social Science, Birmingham, in 1884 (20):
“In a country like England, where land is a limited commodity and has a high value, there will be an ever present danger that space which should be left for the public enjoyment may be reduced into private ownership”

In the case of Epping Forest, the land was already in the private ownership of the lords of the manors and so while enclosure may then have been followed by extinguishment of the rights of the commoners, denying their access to the land, there would appear to have been no rights of open public access anyway to be affected by that enclosure, even though the legal action by the Corporation of the City of London is often described as being about safeguarding public access. In the course of events, the Corporation of the City of London eventually became the owner of the Forest, taking over from the Epping Forest Commission by being given the power through the Epping Forest Act 1878, a Local Act, to buy up the remaining pieces of land in private ownership, and appointed as the Conservator of the Forest and its commons (18). (A Local Act only applies to a person or an organisation – in this case the Corporation of the City of London – and is not like a public general law that applies to everyone.)

It was in this Act that the public were given the statutory right to use Epping Forest as an open space for recreation and enjoyment, and which placed a duty on the Conservators to keep the Forest unenclosed, not built on, and which was inalienable (it could not be sold). The Act also disafforested Epping Forest, with the deer being put into the ownership of the Conservators “to be preserved as objects of ornament in the Forest”. While some of the commoner’s rights were restrained under the Act, such as cutting down trees, digging gravel, clay and loam, and especially lopping and topping, the livestock grazing under the rights of common of pasture was expressly allowed to continue (see Section 5 in (18)).

Following the Act, the Corporation spent the next four years consolidating their ownership and control of the Forest by paying compensation under Arbitration to manor lords and dispossessed owners, giving them an ownership of 5,530 acres of the Forest (11) and by buying out the lopping rights. The end of this process culminated in the visit by Queen Victoria to Chingford on the 6 May 1882 during which she declared (21):
"It gives me the greatest satisfaction to dedicate this beautiful forest to the use and enjoyment of my people for all time"

Permissive trespass or statutory access?

Perhaps there had been a de facto access to the public prior to the Epping Forest Act of 1878, since public recreation had been a minor land-use of the Forest since at least the sixteenth century (8). However, by the 1860s visitors had become more numerous. An indication of visitor numbers was given in a debate in 1871 that was held on the resolution put by William Cowper-Temple for the preservation of Epping Forest (see earlier). He asserted that tens of thousands would come out to the Forest on Sundays, with greater numbers on special holidays” such as Easter Mondays (16):
“It was most gratifying to witness multitudes of the working classes, who had escaped for a day from the smoky atmosphere and the dreary expanse of bricks and dust and dirt called the Eastend of London with parties of children, imbibing health and enjoying themselves intensely in innocent and health-giving pastimes. It was impossible to doubt that a large number of Londoners were benefited in respect of morality, health, and education by their enjoyment of Epping Forest; for health was promoted by pure air and by exercise, morality by innocent recreation taken by the whole family together, and by amusement free from pernicious excitement and degrading associations….”

It will be remembered that Cowper-Temple was a member of the Commons, Open Spaces, and Footpaths Preservation Society (see earlier). However, his own origins were far from humble - the son of an Earl, inheritor of estates, given a peerage - in contrast to the working classes to whom this munificence was directed. Would Olmsted have been comfortable with this patrician view of public enjoyment of open space? Cowper-Temple’s account was challenged for its accuracy by the Essex MP, Sir Henry Selwin-Ibbetson, who recalled that Cowper-Temple had been on the Select Committee that heard evidence that most of the people visiting the Forest were to be found at the different places of entertainment in and near to the Forest, and that the “main portion of the Forest was not so generally resorted to as was supposed” (see (14)). (Selwin-Ibbetson was instrumental in ensuring that the Epping Forest Act, 1878, was passed (10)).

The contribution to the debate from the Chancellor of the Exchequer put paid to the prospects of the resolution succeeding, when he claimed that it would cost £350,000 to buy out the area of the Forest left unenclosed (16):
“It was said that the Government had not done what they ought to do in the matter; but they had to consider the interests of the great mass of the people of this country, who might not unnaturally entertain the opinion that a large and rich metropolis like London was able to pay for any ground which it might require for the recreation of its inhabitants, and ought not to take the money out of the pockets of the nation generally to any considerable extent for that purpose”

Of course, had Government purchased Epping Forest for the nation in 1871, then the public right of access to this open space would have been secured through releasing it from its private ownership by the lords of the manors, under which I doubt that a public right of access ever existed. The public’s access to Epping Forest was a key issue for the two Select Committees of the 1860’s (12, 13, 14). Evidence given by various witnesses attested to the “immense number” of people who came out on a Sunday and Monday; to the parties of children who were brought in to the forest by horse-drawn vans; and that this access had existed since “time immemorial”, or at least since the time of the Norman Conquest. Witnesses were repeatedly asked by the Select Committee members whether there had been any signs up in the Forest warning of trespass and forbidding access, or whether there was any challenge to members of the public while they were there – there had been none. William Henry Black, an antiquarian, suggested that the Charter of the Forest from 1217 gave a right of access to a Royal Forest (22). This right was given only to freemen (perhaps 10% of the population at the time). It was, however, only similar to that of a commoner in having access to a commons to exercise his rights to tend his animals or collect firewood. It did not give a right to free access.

Many Acts were considered in deciding whether a right of free access could exist, or could be given, such as Chapter 4 of the Statute of Merton from 1235 that established commoners rights (23); the Crown Lands Act 1829 that prohibited Royal Forests from being used for recreation and exercise (24); and the Inclosure Act 1845 that did have a provision for public access after enclosure of a common, albeit only a small area being set aside for recreation (25). In the main, those in official capacity in relation to Royal Forests or Inclosures were firm in believing that there was no right to roam - servitus spatiandi – including George Wingrove Cooke, Commissioner of the Consolidated Tithe, Copyhold, and Inclosure Committee, and James Kenneth Howard Commissioner of Woods and Forests, as well as Joseph Burrell, a barrister specialising in property law, the barrister Philip Hemery le Bretton, and Andrew Alfred Collyer-Bristow, Steward to the Lord Warden of the manors. Collyer-Bristow averred that while there were no free rights of use, the people of some local parishes “might be permissive trespassers” because of their long use, but they had not acquired any rights through that use. It is not surprising that the Select Committee reporting in 1865 considered that the “rights of the public at large” as regards exercise or recreation upon the commons or open spaces was “vague and unsatisfactory” (14).

It’s not been an ambition of mine to become familiar with the historical legislation governing commons, but a means to instate a right of free public access to some commons was given a few years later in the Commons Act 1876, but before the Epping Forest Act 1878. It comes under the provisions in the Act requiring orders for schemes for regulation of commons, and for orders for enclosure, to consider whether those applications would be for the benefit of the neighbourhood (26). The Act defines some terms and conditions that could be incorporated into the orders – the “statutory provisions for the benefit of the neighbourhood”. These included free access to any particular points of view, and the opportunity of playing games or other forms of recreation “at such times and in such manner and on such parts of the common as may be thought suitable”. The Act also guides applicants for orders, on the information that should be provided in support of the application on the benefit of the neighbourhood. This included the number and occupation of the inhabitants of the parish or place in which the common was located; the population of the neighbourhood, and the distance of the common from any neighbouring towns and villages; the intention of the applicants to propose the adoption of all or any of the statutory provisions as defined by the Act for the benefit of the neighbourhood; and whether there was any space other than the common being available for the recreation of the neighbourhood. The Commons Act 1899 extended the incorporation of any of the statutory provisions for the benefit of the neighbourhood to the power of district councils to make a scheme for regulation of a common (27).

It seems to me that those rights of access under the provisions for the benefit of the neighbourhood were highly conditional, being dependent on the level of altruism of the owner of the common. Some 36 commons in England and Wales were regulated under the 1876 Act, and they vary greatly in the extent of access that was granted (28). It was thus not until the National Trust Act of 1907 (another Local Act) that the first obligate statutory right of public access was granted to commons, albeit only to those commons owned by the National Trust (29):
“… shall at all times keep such property unenclosed and unbuilt on as open spaces for the recreation and enjoyment of the public”

The public were first given a statutory right of access “for air and exercise” over commons and waste lands irrespective of ownership in Section 193 of the Law of Property Act of 1925 (30). However, even those rights were restricted to commons that were in the Metropolitan district of London, or in a borough or urban district, and were thus chiefly those in or close to urban areas (my local moor is a s193 common). These “urban commons” amounted to only one fifth of all common land, and thus it was not until the Countryside and Rights of Way Act of 2000 that the right of public access “for the purposes of open-air recreation” was granted for all registered commons (31). Under the provisions of Section 15 of this Act, Epping Forest is regarded as having had existing access rights, and which thus take precedence over the Open Access rights of the Countryside and Rights of Way Act. This would be due to the provisions for public access in the Epping Forest Act 1878, which would be recognised under the statutory provisions for neighbourhood benefits in schemes for regulation under the Commons Act 1899 (27).

So what was the neighbourhood benefit derived from having statutory access to Epping Forest? Cowper-Temple, in speaking to his resolution (see above) described Epping Forest as (16):
“7,000 acres of primeval forest land, clothed, in some parts, with fine forest trees and a very rich underwood, graced with a picturesque beauty which art could not imitate”

Could it have been anything like the primeval forest land that Cowper-Temple described, when it was a commons grazed by cattle, its trees lopped for firewood? Was Oliver Rackham being sarcastic when, 100 years after the Epping Forest Act, 1878, he asserted that Epping Forest was one of the first "wild" public open spaces” (8). While the Conservators had bought out the lopping rights, the greater freedoms of public access gained through the Epping Forest Act, 1878, would have to be shared with the cattle. It was thus a farmed landscape, and would continue to be so as long as the commoners exercised their rights to pasture.

The restoring power of nature

Within a few years of a statutory right of public access being gained, Edward North Buxton wrote a Guide to the Forest, a first edition published in 1885 (10). Buxton had lived all his life in one or other of the Forest parishes; he had over the years explored its every area; and was one of the original ordinary members of the Essex Field Club, a naturalist society founded in 1880 (32). He wrote the guide because he saw how few of the summer visitors to the Forest ever ventured far from their point of arrival by train or vehicle. The book is a marvellous compendium of mapped walks, and illustrated details of the flora and fauna (10). He ventured a few comments about the Forest in relation to its future, echoing the consensus that “the Forest shall remain a forest and not be civilised into a park” but going further in asserting that “it is one of the most important duties of those who have the control of the Forest, to see that the restoring power of nature has fair play as soon as possible”

Buxton was scathing about the past practice of pollarding on the Forest, noting that there was hardly a hornbeam tree in the Forest that had not been periodically beheaded, and welcoming the cessation of pollarding since the Forest had come under the control of the Corporation. He considered pollarding a “destructive custom”; a “cruel treatment”; as “reckless and unsparing”; a “periodical mutilation” and “destructive of all variety and grandeur” leading to the “artificial” and to the “unpicturesque”. Buxton described an area of woodland in the Forest as appearing as though it had been “mown with a scythe”. He noted that the woodland would require many years of careful attention “before it resumes its natural aspect”. Natural aspect has a special significance for the Forest, since the Epping Forest Act, 1878, put a duty on the Conservators to “at all times as far as possible preserve the natural aspect of the Forest” (see Section 7.3 in (18)).

Buxton periodically brought out revised editions of his Guide, and with his fifth edition in 1898, he included a chapter on the Management of the Forest. He noted that the management of the Forest by the Corporation had been subject to criticism that he thought at times was incorrect or ill-informed. Thus his chapter “examined the debatable questions of policy and principle upon which the well-being of the woodland and its continued natural character depend” (33). Buxton laid out his views on management under a number of different headings. He saw that it was the great diversity of aspect, soil, and degrees of moisture in the Forest - the edaphic, topographic and climatic factors - that gave rise to the variety in vegetation in the various woodland areas, and thus were an important part of the natural aspect. The aim should be to “preserve, and emphasise, this variety, which constitutes one of the greatest charms of our woodland”. On the preservation of natural features, he was clear what characterised those features - “in a natural forest we should preserve those features which are not of man's doing”. Buxton gave as an example the retention of dead and decaying trees arising from old age and windthrow. He cited his experience from exploring one of the largest natural forests in Eastern Europe:
“Here, to my mind, the chief beauty resides, not in the standing trees, but in the giants that lie prone among their roots. Many of them have lain for several centuries. They are gorgeous with moss and lichen; their great trunks are seed-beds for their descendants, and they tell a story of mighty hurricanes and snowstorms which we should miss, if it had been possible to remove them. Such features are the characteristics of all virgin woodlands. Our Forest is also a document of nature with its tale to tell. Its failures, its ruins, should be preserved, as well as its vigorous youth. It should not be trimmed and garnished”

This was a visionary understanding of the role of deadwood in the ecology of woodlands, far in advance of the general recognition that would come some 80 years later (34). Buxton was concerned about the importance of conservation and encouragement of all wild life, regarding the Forest as a sanctuary for birds and beasts, including the predators as well as the often unseen and disregarded species of wetland and woodland interior:
“Fairplay to all things that fly, run, creep, or swim, should be our motto, so that man, who is at times the most predatory animal of them all, may study, and learn to respect them. Nor should the lower forms of life be forgotten, for these also offer a wide field for profitable research to those who inquire into their secrets; e.g. let us leave intact those moist places which teem with life invisible to the passer-by”

Buxton continued to highlight the artificiality arising from the past pollarding, regarding it as a “widespread interference with the natural aspect of the Forest” and supported the removal of this artificiality by thinning-out the denser areas of pollarded trees to allow for the growing-out of the remaining pollards. The pollard trees could only have existed in such close, unnatural proximity because of the practice of pollarding. In support of this thinning, he quoted the words from 1864 of an unnamed “competent observer” (himself?) about the pollards and what effect they would have had on the perception of the Forest by a visitor coming out from London (the words came from an article on “The Forest of Epping” in Cornhill Magazine for March 1864 (35)):
“if he begins to indulge any fancies about primeval wastes unspoiled by man, a glance at the trees will correct him. They are not, strictly speaking, trees at all, but strange, fantastic vegetable abortions”

In looking to the future of the Forest, Buxton was opposed to planting trees when “nature is well able to sow her seeds in the most favourable manner” and that “a grove thus produced is infinitely more picturesque and diversified than a planted wood, because the trees are of all stages and ages of growth, and the fittest survive, perhaps after some struggles, of which they bear the signs”

He objected to the planting of foreign trees, or “abnormal” varieties of native ones. He was particularly scathing on the introduction of conifers into a deciduous forest that were not suited to either the soil conditions or climate - the natural aspect - claiming they gave an “impression of artificiality and of forced culture”. Above all, Buxton recognised the long-term nature of woodland processes, that their stewardship needed imagination and a “full knowledge of natural processes”, and that the trajectory of change initiated in the woodland with the thinning and the withdrawal of repetitive management needed to be looked at through a timescale that went past that current generation and on into fifty or a hundred years hence.

This all-embracing visionary ambition for the Forest from Buxton would likely have found favour with Olmsted. It had though, at some point, to come up against the immoveable element of the Commoners' Right of pasturage, which Buxton regarded as “one of the most thorny questions” that the Conservators had to deal with. He noted that the natural regeneration of trees in the Forest was at the mercy of grazing by the commoners cattle. His solution was temporary fencing to give protection for the self-sown trees from browsing. While this kept the commoners' cattle out, the “slight” nature of the fencing was less effective against the deer. He proposed an experiment using “valueless” pollarded trees after felling, but with all their branches left on. Groups could be “thrown down” such that they protected tree seedlings until they had grown through the branches to a height of four or five feet. His idea was not supported, even though it has echoes in that aspect of a dynamic natural forest where dead and fallen trees provide such protection.

Buxton’s only recourse about the livestock grazing was to caution the Conservators to ensure that the Forest was not “surcharged” by commoners' cattle. What he meant was that the Conservators should ensure that the number of cattle on the Forest be controlled – “should not be increased to the starvation point” - through the regulatory measures that were available to them to ensure that the Forest was not over-grazed. His particular concern was that the commoners’ cattle should have access to enough feed off the Forest during the winter months, or they would “in the struggle for food, seriously injure the young trees”

The concept of natural aspect outlives its usefulness

Buxton’s legacy of empathy with the natural aspect did not endure through the contemporary development of the conservation industry in England of the second half of the twentieth century. Colin Ranson, who covered Essex for the Nature Conservancy Council (the fore-runner of English Nature) conceded when writing about the nature conservation of the Forest in 1978 that Buxton had influenced Forest management for much of its first sixty years (36). However, Ranson was uncomplimentary about what he saw as Buxton’s approach, which he characterised as “nature should take its chance” and accused Buxton of taking wildlife for granted. He imputed an “innocent neglect” by Buxton that he considered had resulted in a steady loss and decline due to the usual dogmatic observations of scrubbing up and shading – no allowance that this was a phase of the processes a woodland goes through in reversing the effects of human extractive use. If there was a loss of groundcover species, it was a reflection of the high proportion of beech in the Forest casting a greater shade than most trees, and a longer timescale involved in the return of woodland species, in contrast to the easy mobility of open landscape species. Why is there so much beech, when the evidence suggests that the original prehistoric wildwood was dominated by lime? Lime was abundant in the area of Epping as late as the Anglo-Saxon period (8). That it declined and was replaced by beech and hornbeam is because of the rise of the wood-pasture system in the Forest. Lime is sensitive to grazing, and other trees rare in the Forest mainly for this reason are ash, hazel and elm, although the elm would have been lost to disease in 1970s even if it had survived the grazing.

Ranson, along with other critics of Buxton, could not conceive of the Forest in terms of its natural aspect, seeing instead only the loss of the totems of their conservation ideology. Ranson believed the natural aspect was a “duty…almost incapable of being discharged”; that the consequences of the changes in management of the pollards showed that the “natural aspect is as elusive as ever”, and it was an “abstract concept” that because it had put those totems at risk, should have been eliminated before 1900 by amending the Epping Forest Act, 1878.

Oliver Rackham was an admirer of the pollards for their antiquity, distinction and “beauty”, but mostly it appears to me that his admiration was because they were a record of historical land use. Writing at the same time as Ranson, he bemoaned that the Conservators had the power under the Act to terminate pollarding, which they had promptly used. Given that, he saw it illogical that the common rights of grazing were allowed to remain. However, he favoured the grazing, presumably because it also created a record of historical use (8):
“many historic features had been sacrificed in the pursuit of a "natural aspect" which was always speculative and is now seen to be an illusion. The "natural aspect" clause in the Act may at first have protected the Forest from an even worse fate, but it has long outlived its usefulness and should be reviewed while something yet remains of the historical Forest”

What may also have been in Rackham’s mind was the precipitous collapse in grazing across the Forest, as the 21st century proceeded (see the figure on page 7 in (37)). In 1895, there were 627 cattle and 310 horses pastured on the Forest; 1939 saw 189 cattle and 30 horses, whilst in 1974 there were 299 cattle and only one horse on the Forest (38). The slight upturn in the 60s and 70s was possibly in response to rumours of a compensation scheme (34). During the 1980s the maximum was around 150 cattle, and no horses. By the early 1990’s, as few as five commoners exercised their right, and it was not long before grazing eventually stopped in 1996 (19). Grazing of lowland commons receded everywhere in England over the 21st century, probably as a consequence of a reduction in reliance on what could only be a subsistence-level production, coupled with the marginal nature of the land and the low viability of commons grazing in the economics of contemporary farming – they weren’t called wastes for nothing. Epping Forest gives us an additional reason, the apparent gentrification of the properties qualifying for commoners’ rights around the Forest - the register of commoners in the early 1990’s included a surgeon, a gynaecologist, an engineer, and a clerk in Holy Orders (38).

Buxton died in 1924, and thus did not live long enough to see his “thorny question” resolved through the voluntary decline in grazing pressure on the Forest. He will also have missed the changes on the Forest that were a consequence of that decline, whereby the reducing pressure of grazing allowed greater opportunity for young trees to survive, and for the woodland ground flora that Buxton had catalogued in his Guide, to have begun distributing out from the areas that must obviously have been less accessible to grazing than others (10). In the mid-80s, R.L. Layton of the Epping Forest Conservation Centre sought to quantify the effects of this reduction of grazing pressure by comparing it to thresholds that had been established for woodland regeneration in the New Forest (39). He combined the numbers of deer, cattle and horses on Epping Forest each year into a measure of that grazing pressure, his subsequent graph showing regeneration taking place after the mid-1920’s. Layton conceded that he had no way of substantiating the precision of this finding, other than the occasional written observations of tree regeneration across the decades in specific locations, but he did make comparisons of mapping from the 1890s, and of a photographic record from c. 1900, with the contemporary vegetation, that revealed areas of infill of new woodland.

The era of managerialism

The woodland regeneration is testimony to the removal of a constraint on ecological restoration. However, as the 1990’s came in, all pretense at upholding the natural aspect of the Forest was thrown aside in favour of “man’s doing” as the approach to nature conservation. The Conservators were persuaded to embrace “more positive management actions” with 1991 seeing many of the Forest's grasslands cut, and relatively large areas of pollard trees re-cut (38). Mark Hanson, a Past-President of Essex Field Club, was the editor of a book at that time, entitled Epping Forest: through the eye of the naturalist (38). One of his own contributions to the book was a revel in the historical minutiae of pollarding. He leaves no one in doubt about the object of his admiration when he asserts that the woodland component of a wood-pasture system is of outstanding importance to wildlife conservation in Britain. He bases this on the supposedly superior qualities of pollards in Epping Forest because of their support for species associated with large, old, partly decaying trees – “Old pollard trees support various types of micro-habitat”. He regards natural, unlopped trees as “less ecologically interesting”. It is as if the act of pollarding in itself is the signal event that creates this biodiverse assemblage on the trees. He gives the example of rot-holes that develop when living tissue is exposed and invaded by fungi following the loss of a branch from a tree, and which becomes home to other fungi and to beetles. Except that he admits that the same thing happens when branches are lost naturally. Thus what he is really advocating is the damaging of trees to increase the probability of niches. This is the equivalent of putting up bird boxes, but is more destructive. He also asserts that the long term presence of the pollards is what gives the Forest its ancient characteristic, as is usually associated with a long continuity of tree cover. That too did not depend specifically on the pollarding of the trees.

In his section on the management of the Forest, Hanson used the conservation industry buzzword “mosaic” seven times to describe what was the past state maintained over the commons under the regime of grazing and pollarding, and in his vision of the outcome of the management he now advocated for the Forest (38):
“a mosaic of habitats was maintained ….inter-linked mosaic of habitats…. managed as a mosaic of habitats…..a mosaic of grassland, heath, bog, pollard trees, coppiced woodland and hedgerows…..large scale mosaic”

He wanted to see a reversal in the decline of grazing and a return to pollarding in “an area where there is an integrated management policy which re-creates the mosaic of managed habitats that characterised the Forest up to the late 19th century”. That this meant that the Forest would be again just like everywhere else in our farmed and extracted countryside, was revealed in his reflection that 200 years ago “the Forest's habitats were connected to others outside the boundary of the physical Forest… an unbroken mosaic of habitats……all intimately connected and most importantly, all managed”.

It is of course a convenient contemporary fallacy of the conservation industry to equate past land use with management. Traditional management is the oft-voiced panacea of nature conservation, as is the case now in Epping Forest - “The Conservators have re-introduced traditional management techniques” (40). However, what once was extractive activity for productive use has now, in conservationspeak, become management. This is because the conservation industry’s extractive activity is secondary or unconnected to a productive use - they are just managers, their only harvest being agri-environment subsidy (see later). In the case of Epping Forest, and for all commons, the past use anyway denies an idealistic sheen implied by the word traditional, because the commoners took no responsibility for the land. Hanson records this (38):
“Over the centuries, through the burning of lopped wood and the eating of meat from commoners' animals, large amounts of nutrients must have been removed from the Forest without being replaced”

He also records another means of impoverishment of the Forest that was, in effect, the theft of animal wastes from off the Forest. In 1733, it must have been such a quantity that the Court of Attachments – part of the system for administering Forest law - ordered the keepers to “hinder the poor people from gathering up the dung and laying it in heaps in order to carry it away upon their own lands”

The respite from the cessation of commoners grazing was not to last long. In likely response to the exhortations of the conservation industry, the Corporation re-instated grazing in 2002, circumventing the lack of interest for grazing amongst the commoners by paying a farmer, who also had commons rights, to put his livestock on one of the open areas of the Forest. Starting with 12 English Longhorn cattle in 2002, the numbers rose to 50 by 2004 (41) 36 of those eventually being bought by the Corporation in May 2011 from the grazier, after he gave up delivering conservation grazing on retirement (42, 44). An interim contract was let to continue the grazing during the summer of 2011 and to manage the over wintering of the herd through to the end of March this year (43). A tender process resulted in the same person being engaged in a new “business partnership” from March onwards that would gradually move the service from a 100% subsidised conservation-led non-breeding herd towards the “commercial livestock system” of a breeding herd (42, 45). So much for the Forest being used for grazing by those with commons rights, as was the aim of the Epping Forest Act, 1878.

It would not be a surprise to you, if you follow the unbending course of the conservation industry, that within six years of the resumption of grazing, the inevitable whacking great agri-environment agreement was signed on the Forest in 2008 - Entry Level and Higher level (ELS and HLS) – that over 10 years will bring in £1.69 million for the Conservators (41, 46). The grazing contract was considered by the Corporation to be one of the main delivery mechanisms for the agri-environment agreement with Natural England (42). There is also the Heritage Lottery Fund grant of £4.76m given in 2009 towards the implementation of the £6.8m Branching Out project, a chunk of which will pay for infrastructure, such as 9-13 gated cattle grids needed for the return of grazing to the whole Forest, and to enable a three month extension to the grazing season (41, 47, 48).

The Forest is more than a nature reserve with cattle grazing thrown in

Not everyone has been happy about the proposed ramping up of grazing. The Friends of Epping Forest has the rare distinction of independence of thought. It is a registered charity, established in 1969 to provide an independent voice in the protection of Epping Forest in accordance with the 1878 Act, as well as being a consultative link between the administrators of the Forest and the public. It has over 1,600 members, and its program of walks, regular newsletter and occasional publications further the knowledge and appreciation of the Forest (49). When the Corporation began consulting on the expansion of grazing in 2005 (50) the Friends gave a detailed critique of the proposals in their Autumn Newsletter. Amongst many points, they said they had not seen, neither had they been shown, any substantive evidence to support the level of ecological improvement claimed in Epping Forest following the reintroduction of grazing (51). They were critical that the proposed fencing, cattle grids, gates, and stiles of what would appear as a “heavily grazed farmed landscape” would impose limitations on public access both directly through preventing the characteristic of access at any point onto the Forest, and indirectly by giving the appearance of private ownership. It would carry a message of “subliminal ownership” and restriction of access that was contrary to the “expansive and generous provisions” of the Act, and would likely anyway to be in contravention of the Act. They were concerned that an intensively grazed Forest would need a significant depletion of trees to make way for more grassed area, and a loss of understorey and shrubs combined with a restriction on tree regeneration in what would be left of the woodland. They feared a transformation of the woodland of the Forest into a “savannah” type woodland of open grassland with scattered trees – “a totally different forest”, affecting its appearance and ecology (51):
“The Forest is more than a nature reserve with cattle grazing thrown in. People appreciate it for many reasons including its mystery. Even though one is never more than a few hundred metres from a road it still has a feel of remoteness and escape that would be totally lost were it to be turned into wood pasture, viz grassland with scattered trees”

At issue for the Friends was the notion given by the Conservators that cattle would have roamed everywhere in the Forest. Their view was that, by and large, grazing took place on the open grassy areas of the plains (see earlier) that still existed on much the same scale and on the same locations as today. They did not think that cattle in significant numbers penetrated the woodland areas, whether pollarded or not. I agree, considering the list of woodland flowers identified in the Forest by Buxton that would have been destroyed by grazing, and which thus must have been inaccessible to the commoners’ cattle (see earlier). In their extended comments on the consultation, the Friends pointed to what they thought was the driving force behind the grazing proposals (52):
“There is a view in nature conservation circles that supports the notion expounded in Franz Vera’s, ‘Grazing Ecology and Forest History’, that ‘wood-pasture’ (a more open savannah woodland grazed by cattle) might be more representative of the original natural landscape than closed high forest. However Vera’s argument, that large grazing animals played a large part in this, has not been universally accepted…….We adhere to the view that in modern parlance and understanding, a forest is a place where people expect to see trees and for trees to predominate"

It is interesting to see others pick up on this fallacy in support of the conservation industry’s conservation grazing (see my debunking of "The Vera hypothesis and Nature Development" in (53)). The point about loss of woodland flowers to grazing was picked up by Rackham himself, writing many years later about his scepticism that their survival could be reconciled with Vera's theories. He wondered whether in wildwood, there was some form of compartmentalisation, analogous in outcome to the fencing that existed in medieval parks and Forests that kept deer and livestock out of woodland there. He wrote in his book Woodlands (54):
"It is difficult to imagine a physical barrier, but were the depths of groves no go areas for deer and wild cattle, either because there was not much to eat or because of danger from carnivores?"

The Conservators developed a rationale for the grazing strategy after the first consultation (55). Because of criticism that the fencing could be in contravention of the Act, the Conservators sought a legal opinion. Frank Hinks Q.C., decided that fencing of any nature would in some measure “impede public access and impair the natural aspect of the forest” (56). However, he pointed out that the duty of the Corporation under Section 7(3) to “preserve the natural aspect of the Forest” was qualified by the words “as far as possible”, and that the right of the public under Section 9 “to use Epping Forest as an open space for recreation and enjoyment” was also qualified by the words “Subject to the provisions of the Act”. In that way, Hinks let the Corporation of the hook, that over a mile of wooden fence erected in May 2002 was legal, as would be any further proposals for fencing.

The Conservators put out Phase 1 of the grazing strategy in 2007 as a second consultation, on proposals for extending the re-establishment of cattle grazing to 700ha and increasing the number of cattle further to 150 (57). A map accompanied the proposals showing the position of the miles of new fencing and nine cattle grids that would be needed (58). As with the first consultation, the Friends newsletter of the summer of 2007 showed concern at the potential of the proposals to affect the natural character of the Forest, and was again critical of the ecological as well as historical underpinning used by the Conservators to justify its proposals. They called for an informed professional debate about what grazing could achieve, particularly within the woodlands, how many animals would be required and detailed information on the results of the grazing undertaken to date (57):
The case for grazing is simply not made here, particularly in relation to the woodlands, where no grazing has taken place for many years…….we question their value in grazing the woodlands, particularly given the clearance work that would be required to encourage them to enter the woodland for other than shade. To achieve an open woodland will require substantial clearance of understorey and trees to enable grass to grow for the cattle to graze. In order to keep the areas subsequently open will require much higher numbers of cattle than the 150 animals proposed”

A commercial livestock system

With a majority of consultation response being in favour of the proposals, the Corporation’s next move on grazing involved a Transport Strategy for the Forest developed along with Essex County Council (59). One of the aims of the strategy was “to assist the Conservators in re-establishing commoners’ cattle grazing” by the installation of cattle grids at selected locations. The cattle grids, linked together by miles of new fencing would of course be a means of control in preventing the cattle from straying out of the Forest “whilst being able to graze over as large an area of the central forest as possible” (59). I am struck by the sophistry employed around this transport strategy, that it would “protect the ancient grazing rights” and “protect the traditional grazing management” (60). Well, only in the sense that the new “business partnership” arrangement for grazing would likely fail to become a “commercial livestock system” if the cattle were able to wander off (see earlier).

Essex County Council, as the Highway Authority, submitted an application to the Planning Inspectorate for consent to install 4 cattle-grids and by-passes at the edge of the Forest. The application received 56 objections, and so a public enquiry was held between 22 to 24 November 2011 (43, 61). In its Statement of Case to the Inquiry, the Friends argued that the installation of cattle grids was implicitly driven by the Grazing Strategy, making the Grazing Strategy a material factor of the Inquiry (37). They made their presentation at the Inquiry a further contribution to future discussions about the extensive cattle grazing and wood pasture restoration, which they had regarded after the second consultation as being insufficiently explored, especially as the large new extension to grazing was agreed without the effects of the previous grazing programme ever being properly assessed (58).

They pointed out the numerous flaws in the logic of the grazing strategy, which inevitably showed the cattle grids as being unnecessary (37). They questioned whether it was right to restore the Forest to an open woodland pasture, when their view was that the Forest consisted of denser woodlands (groves), plains and open grasslands and heaths with occasional wetlands - the presence of the groves indicating that not all of the Forest would be sufficiently open to support grazing animals. Their conclusion was that the nature conservation interests of the grazing ideology could be maintained by grazing the grasslands, and without grazing the whole of the Forest. What they sought was a consideration of some fundamental questions that were being overlooked in the drive to implement conservation dogma (37):
"While there is little dispute that historically, herbivores played a part in landscape regeneration and the nature of natural woodland, the key questions are:
a) whether they played the dominant part, in comparison to fire, wind or flooding
b) and even if they did, whether that meant woodlands were much more open then (i.e. a savannah with scattered veteran trees)
c) and whether, even if they were more open historically, whether the restoration of wood pasture should be towards a savannah type woodland”

Another turn in the fate of the natural aspect

The Inspector ruled for the installation of cattle grids. Amongst the conclusions he came to in making his decision, based on the submissions before him, was (61):
“The proposed increase in grazing has been supported by the Epping Forest Grazing Rationale & Strategy as being required for the future conservation and enhancement of Epping Forest’s natural aspect”

This is another turn in the fate of the natural aspect of Epping Forest, from being the wild nature of Buxton’s vision (edaphic, topographic and climatic factors); the inconvenient irrelevance and illusion of Ranson and Rackham; being ignored by Hanson, the arch proponent of managerialism; to where it now becomes the characteristic of a farmed landscape under an agri-environment scheme. In his submission to the Inquiry, Paul Thompson, Superintendent of the Forest, wanders off into the “nature of aesthetics” in his defining of the natural aspect (62). However, in the end, he concludes that the deliberate listing in the Epping Forest Act, 1878, of “pollards, shrubs, underwood, heather, gorse, turf, and herbage growing on the Forest” (section 7.3 (18)) are what constitutes the characteristics of the Forest and thus its natural aspect, which is a “relative naturalness” arising from “the influence of human activity, particularly the exercise of common rights, through the grazing of animals and pollarding”

Dr Jeremy Dagley, Conservation Manager for the Conservators, asserted in his submission that the cattle grids were “necessary for the achievement of a step change in the levels of grazing required as a vital part of the future conservation and enhancement of the Forest’s natural aspect” (63). In a sleight of hand, Dagley connotes this grazing as being the natural way to maintain the vegetation of the open areas of the Forest, asserting that the commoners grazing had been a "naturalistic grazing that had been exercised across the Forest for many centuries", thus equating what is to be a “commercial livestock system” (see earlier) to “grazing and browsing in a near-natural (naturalistic) way” and repeating the term “naturalistic grazing” three times. Naturalistic grazing is of course another of the contemporary sophistries of the conservation industry, and is connected to their use of Vera's theories in support of conservation grazing (see earlier, and my review of naturalistic grazing versus natural processes in (64)).

By now, the divergent aims and entirely different outcomes between Epping Forest and Yosemite will be clear to you. Today, the City of London Corporation asserts that it was the commoners grazing rights that saved Epping Forest from destruction (63, 65) the implication being that the public would have lost their “permissive trespass” had the Forest been enclosed and the commoner’s rights extinguished. It is such a painful irony then, that this celebrated right of public access to open space in England evolved on the back of a commons, a privileged system of land use based on the rights of a few to exploit land they did not own. This is not the “rich people” that Olmstead identified, but it is a system of access and use rights that did not apply to everyone. Consequently, when the Epping Forest Act, 1878, placed the forest in the beneficial ownership of the City of London Corporation, and with a statutory right of access for all people, it did not set the land free from that commons system of land exploitation. Thus the public’s freedom of access had to be shared with cattle.

Contrast that with what Olmsted was proposing for Yosemite. He realised how easily a few men could destroy such a place for their own material gain. Thus Olmsted argued that “portions of natural scenery be properly guarded and cared for by the government”, that “laws to prevent an unjust use by individuals of that which is not individual but public property, must be made and rigidly enforced” and that there should be a duty to make it widely accessible through it being “held, guarded and managed for the free use of the whole body of the people forever” (2).

I would suggest that the inherent contradiction between free access, as well as the natural aspect, with the presence of cattle resides in the “other purposes” of the full title of the Epping Forest Act, 1878 - An Act for the Disafforestation of Epping Forest and the preservation and management of the uninclosed parts thereof as an Open Space for the recreation and enjoyment of the public; and for other purposes” (18) Intriguingly, Superintendent Thompson missed off this last bit of the title in his submission to the Planning Inquiry (62). The more I think about the events at Epping Forest, the more it seems to me that it was really the “other purposes” that were the driver for the Act, and not just some high-minded aim for public access. Was not the ideal of “that which is not individual but public property” lost at the outset for Epping Forest, when the rights to commons grazing were retained in the Act?

Even more painful irony comes from the fact that any wildness in the natural aspect that may have developed over the last century, as the grazing by commoners tailed off, is to be snuffed out by an agri-environment agreement that is turning back the clock to the 1870s – it is funding felling, coppicing and pollarding, clearing scrub, re-creating heathland, and a large expansion of grazing from its initial reinstatement. The usual dogma prevails – that woodland areas are too densely shaded and so must be opened up by coppicing, felling, pollarding and managing rides and glades; and the open areas of grassland and heathland are being lost due to the cessation of grazing and the encroachment of “invasive” birch, and thus must be cleared and grazed.

That this must sound familiar is because it is the tale of every lowland open space in England that the public have gained a statutory right of free access to under the various Commons Acts, and then more recently under the Countryside and Rights of Way Act (see (66)) and including unfortunately now parts of the Public Forest Estate in England (64). It is our legacy that most of our free access to open space is tied to agriculture. That many of the lowland commons are now in public ownership with local authorities, is the result of their marginal agricultural value and the lack of return on private ownership of that land, and perhaps also because their transfer to local authorities was facilitated by the Open Spaces Act 1906 (67) which, although it was supposed only to cover unoccupied land such as abandoned commons, was also applied to commons with active graziers (68). Even when in public ownership, if it is a commons, then the rights of the commoners supersede those of the public. What we have as the "whole body of the people" as Olmsted would say, are only the rights of public access to lands irrespective of ownership that are shackled to an agricultural use that, even if it has declined over recent decades, is now increasingly being replaced by a nature conservation that is but the same as that agricultural use. This is the case for my local moor.

The parallels with Rock Creek Park

While I was researching Epping Forest, I kept thinking about the parallels with Rock Creek Park, because it also runs NS, and is surrounded by an urban population because it divides Washington DC from Georgetown. I used to run through the Park when I lived in Washington for a short period in the mid-1980s. The origins of the Park date back to 1866 when the United States Senate directed its Committee on Public Buildings and Grounds to identify a location for a new presidential mansion to replace the White House, and which had enough surrounding land to be public grounds for a park “for the sake of healthful recreations” (69). The idea of the presidential mansion fell by the wayside, but the valley of Rock Creek was identified for the park (69):
“All the elements which constitute a public resort of the kind can be found in this wild and romantic tract of country. With its charming drives and walks, its hills and dales, its pleasant valleys and deep ravines, its primeval forests and cultivated fields, its running waters, its rocks clothed with rich fern and mosses, its repose and tranquillity, its light and shade, its ever-varying shrubbery, its beautiful and extensive views….”

After a number of stalled attempts, a Bill was signed by President Benjamin Harrison on September 27, 1890, that land within Rock Creek valley “be perpetually dedicated and set apart as a public park or pleasure ground for the benefit and enjoyment of the people of the United States, to be known by the name of Rock Creek Park” The park would "provide for the preservation from injury or spoliation of all timber, animals, or curiosities within said park, and their retention in their natural condition, as nearly as possible" (70). The Bill created a Commission to select land from the valley for the park, and authorised payment for it. The Commission acquired 1,605 acres at a cost of $1,174,511, and on December 13, 1894, handed it over to a Board of Control for Rock Creek (69).

On April 29, 1895, before building any roads or taking other steps to facilitate public access, the Board of Control adopted the first regulations for use of Rock Creek Park, and which would guide the transition from private property to public landscape (69, 71). These stressed public safety and conservation of the natural beauty of the park, by prohibiting off-road use by carriages and horse riders, placing a 10mph speed limit for the drivers or riders of carriages, bicycles, and horses, and prohibiting firearms or fireworks, hunting, trapping, fishing, the cutting or defacement of vegetation, and the grazing of livestock. Thus, from its inception Rock Creek Park was to be a landscape “that combined the conservation and recreational missions of a wilderness preserve and urban park” (71)

The two land owners in the Park area vacated their large mansions soon after the Bill was passed and guidelines were introduced for the gradual relocation of the 20 tenants living on or using property in the park (71). The Board of Control continued to lease tracts to tenant farmers, but in 1912 it ordered the termination of the remaining tenancy agreements. Livestock grazing came to an end.

In 1917 the Board of Control, in the absence of a comprehensive plan, and wanting to avoid deterioration of the natural characteristic of the Park, commissioned the Olmsted Brothers to prepare a planning study for the future development of Rock Creek Park. These sons of Frederick Law Olmsted, Frederick Jr and John, had worked with their father in his landscape architecture practice. In 1898 after their father had retired, they changed the name of the practice to Olmstead Brothers (72). Fredrick Jr. made a name for himself through becoming a member of the Senate-appointed Park Improvement Commission for the District of Columbia, commonly known as the  McMillan Commission, and which developed the McMillan Report in 1902 “for the development of the entire park system of the District of Columbia”. Olmsted was also an adviser on, or the designer of a number of elements of the proposed park system that were eventually built, many becoming prominent Washington landmarks such as the White House grounds, the Federal Triangle, the Jefferson Memorial, Roosevelt Island, and the National Cathedral grounds. (73). He was also instrumental in drafting the legislation that set up the National Parks Service in America. He drew on the legacy of his fathers vision in the report on Yosemite when he crafted the definition of purposes for the National Park Service Organic Act 1916 that established a unified system of national parks and a professional bureau to manage them (74).

The Olmsted Report was completed in December 1918. The opening paragraph of the Foreword sets the tone of the report (75):
"The dominant consideration, never to be subordinated to any other purpose in dealing with Rock Creek Park, is the permanent preservation of its wonderful natural beauty, and the making of that beauty accessible to people without spoiling the scenery in the process”

The report supported protection of the park’s natural values:
"It is unnecessary to praise the very exceptional natural beauty of Rock Creek Park, because it is well known and widely appreciated, but it is important to emphasise the fact that it is upon the subtle qualities of this essentially wild and natural beauty that the public value of the Park mainly depends. The real justification for this large park is unquestionably found in the recreative value of its natural qualities - large stretches of forest, the river valley, dark ravines, steep and rolling hills, and occasional meadow lands - and no use or exploitation or development of any sort can ever be right that is not based upon this fundamental conception”

It gave a fascinating analysis of the scenery, identifying that it was made from two parts, the larger landscape pictures and the more intimate details, somewhat reminiscent of their father’s appreciation of the “natural scenery” of Yosemite:
“First are the larger landscape pictures made primarily by the ground forms - the topography - but supplemented and enriched by the masses of woods and stretches of open field. …The landforms of the Rock Creek Valley – and this valley with its ramifications furnishes all of the larger scenery of the park – are of considerable variety. Here the valley is narrow and gorge-like, with rocky forest clad sides dropping abruptly to the Creek which breaks and tumbles along over a stony bed………The other is that more intimate and smaller scenery which is based not upon major hills and valley, but rather upon the details of ground form and upon the character and beauty and happy combinations of trees and shrubs and flowers that grow there”

The approach then taken by the brothers in the report was to divide the Park up into Primary Landscape and Administrative Divisions, giving a broad brush identification of the topography and predominant land cover of those divisions and discussing briefly their use by the public and their development. Thus Division A on the map was the Valley Section that was “topographically and psychologically the backbone” of the Park, and where they did not want to see any use develop that would “injure the present charm and beauty of this valley scenery” In terms of size, the two largest were the 300 acres of Division C - Woodland for Intensive Use – a plateau woodland area “well adapted for exploration and enjoyment by pedestrians”; and the 450 acres of Division E - Wilder Woodland – where the “natural character of its forests should be preserved to the highest degree” The Olmsteds considered that the inaccessibility and topographical character of this division did “not invite an intensive use by the walking public”. They suggested that walkers should stay on the paths in this division to ensure the “preservation of the finer details of the natural woodland scenery”

In terms of specific management proposals, they mapped out four distinctive landscape types on the Park that that they wished to see retained. The mapping of these types cut across all the administrative divisions. Type I indicated areas where the general conditions and characteristics of the natural forest should prevail. This category of landscape dominated the land area of the Park. The other types were more open woodland areas of scattered trees and grass (Type II) uplands areas of semi-open growth with primarily cedars (Type III), and open grassland areas (Type IV). In an echo of Buxton’s exhortation that Epping Forest should benefit from the “restoring power of nature”, and that “in a natural forest we should preserve those features which are not of man's doing”, the suggestion given by the Olmsted's in the report for the maintenance of Type I areas was:
“In type I, the normal forest conditions should be maintained in so far as possible: and that means primarily a policy of hands off”

In concluding the report, the Olmsted’s briefly discussed the appropriations that would be needed from Congress to meet the costs of the Park. They did not want to see a large expansion of activities or improvements in the Park. For them the “inherent value of the naturalistic "undeveloped" qualities of the park cannot be overestimated. For in those qualities lies the essential justification for all that has been done and spent, for all that will be done and spent to give this great park to the people”

The Olmsted report was readily accepted by the Office of Public Buildings and Grounds, which took over administration of the Park that same year, and was incorporated into the management policies for the Park (71). Rock Creek Park eventually came under the control of the National Park Service in 1933 (69).

If you want a measure of the natural aspect of Rock Creek Park today, it is home to a range of native wild mammals including Whitetail deer, Eastern cottontail (a rabbit), both the gray and red fox, beaver, raccoon, opossum and Eastern chipmunk (76). Amphibians and reptiles include spring peeper (a frog) wood frog, spotted salamander, red-backed salamander, box turtles and rat snakes (77). Year-round bird residents are the great horned owl, red-shouldered hawk, pileated woodpecker, American crow, American robin, northern cardinal, and song sparrow (77). Coyote turned up in the Park in 2004, and have been seen continuously since, as have their dens (78). Coyote eat carrion and hunt small mammals, amphibians and snakes. Their appearance in the Park coincided with the mysterious disappearance of the carcasses of deer killed on roads around the Park (79). As the coyotes entered the Park on their own, they are subject to the same protection as other native wildlife under Park regulations (78).

The Park is a forested valley in the Eastern deciduous forest ecosystem, with 85% of its 1,754 acres in natural forest that has not been harvested or disturbed for the last 120 years (78). The most widespread forest type across the Park has white oak, beech and tulip poplar in its canopy, but with also hickory, black gum and sweet gum (80, 81). The sub-canopy has dog wood, witch hazel and American holly, with maple-leaved viburnum present everywhere in the shrub layer of this forest type. The ground layer is dense and diverse in places and includes a number of lovely wildflowers such as Mayapple,  jack-in-the-pulpit, cucumber root, Solomon's seal, false Solomon's seal, bloodroot and bellwort, along with Christmas fern, Virginia creeper and the parasitic squawroot (80, 81). Floodplain forest occurs along the narrow stream corridors in the Park, and has American sycamore as its main canopy tree, with some box elder, tulip maple and red maple (80, 81). The sub-canopy has green ash and some river birch. The shrub layer is dominated by spicebush, with some blackhaw and black willow. The ground layer plants are indicative of the moisture here, including skunk cabbage, jewelweed, Virginia bluebell, mild water-pepper and wood-nettle.

It may be somewhat unfair to contrast the natural aspect of Rock Creek Park with Epping Forest, but the spirit of wildland coupled with the absolute commitment to public access that so infected the ethos of open space in America, then as now, and which Buxton had some measure, makes Epping Forest a very pale comparison. Must we condemn ourselves always to such a paucity of vision that we never give Buxton's “restoring power of nature” a chance? What if cattle grazing had come to an end in Epping Forest at the same time that the public were given "the right to use Epping Forest as an open space for recreation and enjoyment" and that the management of the Forest had kept faith with Buxton's vision for the natural aspect?

Mark Fisher 21 November 2012

(1) U.S. Statutes at Large, Vol. 13, Chap. 184, p. 325. "An Act authorizing a Grant to the State of California of the Yo-Semite Valley, and of the Land embracing the Mariposa Big Tree Grove.'" [S. 203; Public Act No. 159] June 30 1864

(2) Yosemite and the Mariposa Grove: A Preliminary Report, Frederick Law Olmsted (1822-1903) August 9, 1865

(3) Contemplation of natural scenes, Self-willed land January 2012

(4) Forest, Rocks, Torrents. Self-willed land October 2011

(5) Draft of Preliminary Report upon the Yosemite and Big Tree Grove; Typed Transcription of Draft of Preliminary Report upon the Yosemite and Big Tree Grove; and Typed Transcription of Letter on the Great American Park of the Yosemite.

(6) U.S. Statutes at Large, Vol. 26, Chap. 1263, pp. 650-52. "An act to set apart certain tracts of land in the State of California as forest reservations." [H.R. 12187]

(7) The enduring relevance of Octavia Hill. Ed Samuel Jones. Demos 2011

(8) Rackham, O. Archaeology and Land-Use History. In: Corke, D. (ed.) Epping Forest - the natural aspect? The Essex Field Club 1978

(9) Perceval, P.J.S. London's Forest: Its History, Traditions and Romance, London: Dent & Co 1909. Pg 57

(10) Buxton, E.N. Epping Forest. Second Edition Revised. Edward Stanford, London 1885

(11) Hunter, R.H. The Preservation of Open Spaces, and of Footpaths AND Other Rights of Way.  A practical treatise on the law of the subject. Eyre and Spottiswoode, London 1902

(12) Report from the Select Committee on Royal Forests (Essex); together with the proceedings of the committee, minutes of evidence, appendix and index. The House of Commons, 9 June 1863

(13) First Report from the Select Committee on Open Spaces (Metropolis); together with the proceedings of the committee, minutes of evidence, appendix. The House of Commons, 3 April 1865

(14) Second Report from the Select Committee on Open Spaces (Metropolis); together with the proceedings of the committee, minutes of evidence, appendix. The House of Commons, 20 June 1865

(15) History. Open Spaces Society

(16) EPPING FOREST—RESOLUTION. Commons Sitting of 28 April 1871. Hansard Series 3 Vol. 205

(17) EPPING FOREST: Administrative/Biographical history. AIM25 Archives in London and the M25 area

(18) Epping Forest Act - Act for the Disafforestation of Epping Forest and the preservation and management of the uninclosed parts thereof as an Open Space for the recreation and enjoyment of the public; and for other purposes. [8 August 1878] CHAPTER ccxiii

(19) EPPING FOREST Grazing, Corporation of London May 2004
(20) Hunter, R. A suggestion for the better preservation of open space’, paper read at the Annual Congress of the National Association for the Promotion of Social Science, Birmingham, Sep 1884. Published by the Commons Preservation Society, 1884.

(21) Hagger, N. A View of Epping Forest. O Books 2012

(22)The Charter of the Forest of King Henry III, St John's College Research Centre, University of Oxford

(23) Act 20 Henry 3, c.4, conferring certain RIGHTS on LORDS of MANORS, commonly called the STATUTE of MERTON. In Appendix 4, Second Report from the Select Committee on Open Spaces (Metropolis); together with the proceedings of the committee, minutes of evidence, appendix. The House of Commons, 20 June 1865

(24) Crown Lands Act 1829 c. 50 (Act 10 Geo. 4, c. 50, s. 54) A bill to consolidate and amend the laws relating to the management and improvement of His Majesty's woods, forests, parks and chases, of the land revenue of the Crown within the survey of the Exchequer in England, and of the land revenue of the Crown in Ireland; and for extending certain provisions relating to the same to the Isles of Man and Alderney. [4 May 1829]

(25) Inclosure Act 1845 (1845 CHAPTER 118 8 and 9 Vict) An Act to facilitate the Inclosure and Improvement of Commons and Lands held in common, the Exchange of Lands, and the Division of intermixed Lands; to provide Remedies for defective or incomplete Executions, and for the Non-execution of the Powers of general and local Inclosure Acts; and to provide for the Revival of such Powers in certain cases. [8th August 1845]

(26) Commons Act 1876 - An Act for facilitating the regulation and improvement of Commons, and for amending the Acts relating to the Inclosure of Commons. [11th August 1876] CHAPTER 56 39 and 40 Vict

(27) Commons Act 1899 - An Act to amend the Inclosure Acts 1845 to 1882 and the Law relating to Commons and Open Spaces [9th August 1899] CHAPTER 30 62 and 63 Vict

(28) Commons which have been the subject of regulation under the Commons Act 1876

(29) National Trust Act - An Act to incorporate and confer powers upon the National Trust for Places of Historic Interest or Natural Beauty [21st August, 1907] CHAPTER cxxxvi.

(30) Law of Property Act - An Act to consolidate the enactments relating to conveyancing and the law of property in England and Wales [9th April 1925] CHAPTER 20 15 and 16 Geo 5

(31) Countryside and Rights of Way Act - An Act to make new provision for public access to the countryside; to amend the law relating to public rights of way; to enable traffic regulation orders to be made for the purpose of conserving an area’s natural beauty; to make provision with respect to the driving of mechanically propelled vehicles elsewhere than on roads; to amend the law relating to nature conservation and the protection of wildlife; to make further provision with respect to areas of outstanding natural beauty; and for connected purposes [30th November 2000] CHAPTER 37

(32) A short history of the Essex Field Club, 1880-1930, Essex Field Club Special Memoirs, Vol. 7 (1930)

(33) Buxton, E.N. Epping Forest. With Chapters on Forest Management, Geology of the District, Prehistoric Man and the Ancient Fauna, Entomology, Pond Life, and Fungi of the Forest. Sixth Edition Revised. Edward Stanford, London 1901

(34) Harmon, M.E. et al (1986) Ecology of Coarse Woody Debris in Temperate Ecosystems. Advances in Ecological Research 15: 133–302

(35) Epping Forest in the Sixties. Essex Naturalist, Vol. 9 (1895) The Essex Field Club, pg 229

(36) Ranson, C. E. (1978) Nature conservation in Epping Forest. In: Corke, D. (ed.) Epping Forest - the natural aspect? The Essex Field Club 1978

(37) Statement of Case by Judy Adams on behalf of the Friends of Epping Forest. In the Matter of the Highways Act 1980 Section 82 and Schedule 10 And in the Matter of cattle-grids and by-passes within Epping Forest at Wake Road, Cross Roads, Rangers Road and Forest Side. Public Inquiry 22-25 November, 2011. pg 7

(38) Hanson, M.W. (ed.) (1992) Epping Forest: through the eye of the naturalist. The Essex Field Club, London

(39) Layton, R.L. (1985) Recreation, Management and Landscape in Epping Forest: c.1800-1984. Field Studies 6: 269-290

(40) Traditional management techniques, Wildlife and Nature, Epping Forest, City of London

(41) The history of grazing on Epping Forest, Dr Jeremy R Dagley, Conservation Manager, Epping Forest October 2011

(42) INVITATION TO TENDER DOCUMENT Requirement for management of Epping Forest Conservation Grazing Services through a business partnership with the Conservators of Epping Forest. CITY OF LONDON 30th September 2011$FILE/Epping%20Forest%20grazing%20contract%20-%202012%20tender%20doc%20v%20final%2028.09

(43) Friends of Epping Forest Newsletter Summer 2011

(44) Forest Focus Autumn/Winter 2011: The newsletter for Epping Forest, City of London

(45) Forest Focus Autumn 2012: The newsletter for Epping Forest, City of London

(46) HLS agreements live April 2011, Natural England

(47) Epping Forest Branching Out Project, Discovering Epping Forest

(48) Epping Forest is Branching Out, Ancient Tree Forum News April 2009

(49) Friends of Epping Forest

(50) Cattle Grazing on Epping Forest - a consultation document on future conservation management, Corporation of London October 2005

(51) Cattle Grazing in Epping Forest. Friends of Epping Forest Newsletter Autumn 2005

(52) Extended Comments on the Cattle Grazing Consultation Document. Friends of Epping Forest

(53) The revisionism of the conservation industry – expanding the noosphere in Britain, Self-willed land march 2012

(54) Rackham, O. (2006) Woodlands. The New Naturalist Library. HarperCollins

(55) Epping Forest Grazing Rationale and Strategy,Grazing%20Rationale%20and%20Strategy.doc

(56) Cattle Grazing and Fencing. Opinion of Frank Hinks Q.C. April 2006,CATTLE%20GRAZING%20AND%20FENCING.doc

(57) Friends of Epping Forest Newsletter Summer 2007.

(58) Friends of Epping Forest Newsletter spring 2008

(59) Epping Forest Transport Strategy proposals 2009 – 2016. City of London and Essex County Council October 2008

(60) Improving the Forest Management – protecting traditional grazing, Forest Transport Strategy, City of London

(61) Installation of cattle grids and by-passes within Epping Forest at Wake Road, Cross Roads, Rangers Road and Forest Side – Essex County Council. Report to the Secretary of State for Transport, Planning Inspectorate 12 December 2011

(62) Proof of Evidence Prepared by Mr Paul A Thomson, Superintendent of Epping Forest, City of London Corporation October 2011

(63) Proof of Evidence Prepared by Dr Jeremy R. Dagley, Conservation Manager, Conservators of Epping Forest October 2011

(64) Fisher, M. “A review of naturalistic grazing versus natural processes“.Presentation at Europe’s Wilderness Days, PANParks conference, Nagu, Finland, September 2012.

(65) Fencing and grids in Epping Forest. City of London News release 11 November 2008

(66) Heathland MADNESS - the juggernaut of nature conservation, Self-willed land October 2008 – September 2012

(67) Open Spaces Act 1906 (1906 CHAPTER 25 6 Edw 7) An Act to consolidate Enactments relating to Open Spaces. [4th August 1906]

(68) Commons Toolkit Guidance Note 5. Tracing ownership and managing commons with unknown ownership. Natural England 2010

(69) Barry Mackintosh (1985) Rock Creek Park: An Administrative History, History Division, National Park Service, U.S. Department of the Interior, Washington, D.C.

(70) An act authorizing the establishing of a public park in the District of Columbia. 51st Congress, Sess. 1, 1890

(71) William Bushong (1990) Rock Creek Park District of Columbia: historic resource study, US Dept of he Interior/NPS

(72) Chronology of the Olmsted Firm 1857–1979, National Association for Olmsted Parks

(73) Frederick Law Olmsted Jr., National Association for Olmsted Parks

(74) The Olmsteds and the Development of the National Park System, National Association for Olmsted Parks

(75) Rock Creek Park. A report by Olmstead Brothers December 1918

(76) Common Mammals found in Rock Creek Park,

(77) Environmental Assessment for the Rock Creek Park Multi-Use Trail Rehabilitation. U.S. Department of Transportation, Federal Highway Administration, The National Park Service and District Department of Transportation Nov 2011

(78) Coyote Frequently Asked Questions, Rock Creek Park, National Park Service

(79) City Slinkers. Christine Dell'Amore, Smithsonian magazine, March 2006

(80) Fleming, P. and R. Kana (1995) Annotated checklist of vascular plants of Rock Creek Park, National Park Service, Washington, D.C. Castanea 60: 283-316

(81) NBS/NPS Vegetation Mapping Program: Classification of Rock Creek Park. Boston MA: Eastern Regional Office and Arlingon VA: International Headquarters. 1998