The defence of woodland – Forest Neighbours and Gib Torr


The defence of woodland against those who seek its removal is bound up in notions of what a wild landscape would be in Britain. To propose a preference for a wooded landscape, as I did recently (The most natural succession of woodland (1)) had me accused of being as prescriptive as those who seek to remove woodland, such as the conservation industry who favour heathland over trees. It was, however, my way of trying to convey the landscape qualities of the wilderness I have walked in other countries - a difficult task when Britain has so little to offer by comparison. Thus inevitably, if I wish to find some value in existing British landscapes, and pick out places as example, then it tends to be the untended wooded cloughs and ravines that are the left-over marginal areas outside of a predominantly agricultural landscape.

In identifying this, I impose nothing other than an appreciation of what landscapes could be without the influence of agriculture. Thus since man embarked on farming, our natural resource management of “command and control” has been pushing back wild nature to reduce threats to our harvest, and to create outcomes with greater reliability for the prime benefit of humanity. The inevitable result of this holding back of wild nature is a reduction in the range of natural variation of ecosystems in both their structure and function. In effect, we took away the wildness through our conquest of woodland and the continual battle against its return.

Even then, it is not an assumption that every part of our landscapes would be covered with some form of tree cover, since that is not even the case in the wilderness I know, the natural vegetation cover being a function of the depth, moisture and mineral content of the soil, and the climatic exposure of the location. I have walked above the natural tree line in both continental Europe and North America, to alpine areas rich in their own flora and fauna, as well as in other areas where tree growth is just not supported either because it is too dry or too wet. It has to be said though that the two attributes that farming has generally banished from the British landscape – woodland and wetland – are potentially the dominant attributes that would prevail in our conditions. That this is so, at least for woodland, is supported by none less than the UK Biodiversity Action Plan (2):
“The natural climax vegetation (the plant communities which would develop and be present in the absence of human intervention) over much of the UK is broadleaved forest, dominated by trees such as oak, ash and small-leaved lime…...Because the natural land cover of the UK is principally woodland, we have inherited more woodland species than for any other kind of habitat. The structural complexity of woodland creates a great variety of niches, which are exploited by up to two to three hundred vascular plants and perhaps over 5,000 animals (mostly invertebrates)”

Why is woodland seemingly always under attack?

The Forestry Commission (FC) regulates felling by the granting of licences under the Forestry Act 1967 (3). The FC can require restocking, and can set penalties for felling without a licence. While the Forestry Act does not mention deforestation (a net loss of tree cover to other use) there has been a presumption against it, based on the interpretation of intent in the Act of protecting the interests of good forestry, and with promoting the establishment and maintenance of adequate reserves of growing trees. This presumption for the situation in England can be traced through Government policy set out in the document Sustainable Forestry (1994) and in A New Focus for England’s Woodlands, the England Forestry Strategy (1998). The latter specifically states (4):
“We will continue to exercise a general presumption against the conversion of woodland to other land uses unless there are overriding public benefits, for example to restore important semi-natural habitats. In these situations we will seek to ensure that equivalent areas of new woodland are planted in compensation”

Note the intention to seek compensatory planting, because we will return to that, after quickly passing by A Strategy for England’s Trees, Woods and Forests (2007) and it’s Delivery Plan 2008-12 (5,6). Those documents lack an explicit commitment to a presumption against deforestation, and instead show a shift in emphasis by pointing to the substantial areas of priority open habitat that are being restored by the removal of trees and woodland. No wonder the FC had to include a commitment that decisions about restoration of open habitats from woodland in the future would have to be made according to a clear policy on deforestation. Before getting to the development of that policy, two recent examples of intended deforestation give an insight into how the regulatory system is presently working in England.

Drivers for deforestation

An application has been made to fell 6.24ha of broadleaved woodland on Moor Farm Nature Reserve (7) owned by Lincolnshire Wildlife Trust (8). The reserve of 47.70ha is a single unit SSSI for acid grassland – lowland, but the notification describes features such as raised bog and associated habitats of wet heath and acid marshes, with dry heath on sands and gravels, and woodland of birch and oak (9).

The National Inventory of Woodland and Trees shows that about half the reserve is wooded, thus I wondered why the Trust wanted to fell about a quarter of the area of the existing trees since it is not a registered commons, and the SSSI notification implies they are an essential component in supporting a good invertebrate fauna. I contacted the Trust, and Dave Bromwich, their Head of Nature Reserves, replied that he wanted to extend the area of wet heath, which he regarded as more important than the “scrubby woodland”:
”The felling application is to thin a section of scrubby woodland to allow better connectivity of the two regionally important wet heath areas, either side of the woodland block”

I’m not sure how the woodland can be described in that way, since the Trust’s webpage says that much of the woodland on the reserve had developed from abandoned pastures during the last 80 years (8). Dave however told a different story, the woodland area was predominantly wet heath/bog, before being cleared, drained and turned into carrot fields during WWII. He says it reverted back to a drier heathland due to the drainage in the 1960’s, and I suppose it must be implied that it became re-wooded again since then, as natural regeneration took place. Either way, the woodland is probably 50 years old and thus hardly scrubby. This terminology is the usual way of the conservation industry of denigrating secondary woodland arising from natural regeneration when they wish to be rid of it.

The story of the reserve becomes even more complex when I discovered that there have been five prior felling licences granted on Moor Farm, between the years 2000 and 2008, two for clear fell and three for selective felling and thinning. It seems Dave has got the “gardening for nature” bug. A big hole in the woodland can be seen in a satellite image from 2006 that correlates with the recently felled area indicated in the National Inventory of Woodland and Trees, and with the boundary of a felling licence area shown on the mapping system of the Land Information Search facility of the FC (10). There is also some correlation between the areas of thinning shown in the satellite image and the other felling boundary areas, and must represent the result of the three selective felling and thinning licences. It remains to be seen what the impact the current felling licence application will have.

Where once woodland was at the mercy of agriculture and its periodic expansion (see the carrot fields above) the contemporary threat, especially over the last decade - and shown by what is happening at Moor Farm - comes instead from the conservation industry whose slavish adherence to the priorities of the UK BAP creates a demand that every reserve be gardened to maintain a variety of artificial habitats. Partly it’s a problem of scale, but it is mainly an inability to accept what wild nature determines. Would Dave, rather than fell trees, block up the land drainage on the reserve and see what results from natural forces?

A second example comes from Frensham Common in Surrey. The registered common is owned by the National Trust, but a substantial part (333ha) is leased and managed as a Country Park by Waverley Borough Council (WBC) (11). It forms part of a larger heathland SSSI that is also a SPA. The felling application is for 26ha, but this application is on a different register to that of Moor Farm Nature Reserve, as it is subject to an opinion by the FC as to whether an Environmental Impact Assessment (EIA) has to be carried out to avoid significant impact on the environment (12). I have written before of my puzzlement as to why some felling applications have required an EIA, where others have not, even though the criterion for triggering this has clearly been met (Cutting down trees to restore open habitats – only now a policy emerges (13)). The trigger in the case of Frensham is the designation as a SSSI, which in the criteria is regarded as a “sensitive area”. Less sensitive areas have thresholds in felling area of 0.5-1ha above which an EIA is required (14).

If the felling at Frensham has required an opinion on whether an EIA has to be undertaken, then why doesn’t the felling at Moor Farm Nature Reserve also require an opinion on an EIA, since it is also a SSSI?

It is illuminating to delve into the driving force behind the application for felling at Frensham Common. The common is a substantial area of heathland with scattered trees and fringed by mixed woodland. WBC have over the last 9 years received Countryside Stewardship Scheme (CSS) money for management of this common, but the 10-year funding agreement runs out next year (15). In November 2008, they were approached by Natural England who brought with them the inducement of a fourfold increase in the rate of funding if they were to commit to the Higher Level Stewardship Scheme (HLS) that replaced CSS. In applying for HLS, WBC had to produce an extensive management plan that is centred on their maintenance of lowland heath. However, to maximize their income from HLS, they included in the plan an area of 26ha for heathland restoration through deforestation, which is the same as the area sought in the felling licence. When the heathland area of the commons is already about 200ha, you wonder why they would want to add another 26ha? This is a clear case of the funding driving management objectives. I would also like to point out to WBC that it is a bit late to open the management plan for consultation this year when the HLS application with that management plan went in to Natural England last November.

Developing a policy on deforestation

It was inevitable that the FC would have to develop a policy on deforestation in England, considering their responsibility towards maintaining woodland coverage and the increasing pressure they were under from the rate of felling applications to restore open habitats, driven by the England Biodiversity Strategy. The key detail in that strategy is the overall target for restoration of open habitat in England of about 50,000ha by 2015, mostly for heathland, backed up by this reference in the section on Woodlands and Forestry Work Programme 2006-2010 (16)
”Anticipated Outcome by 2010: 5. A significant contribution to the restoration and re-creation targets for open ground priority habitats through removal of trees from appropriate sites”

I wrote last March about the consultation on the deforestation policy, and submitted a response a few months after (Cutting down trees to restore open habitats – only now a policy emerges (13)). All the responses were eventually posted on the FC website, along with a summary that seemed unusually one-eyed in stating the views of those in favour of deforestation, with a minority of evidence stating dissent. Thus the views of Natural England got 38 references in the summary, RSPB got 19, and the Wildlife Trusts got seven. In contrast, the Forestry Regional Advisory Committees together got 18, and the Small Woods Association got just three (17). Prompted by someone who had read my response, I set out to read them all as a barometer of feeling about deforestation. Discarding the “RSPB template” responses, I found 31 tree persecutors (for want of a better description of such an often ideologically imperious attitude in their responses – see particularly (18-22)); 19 moderately in favour of a balanced approach to deforestation; and 54 against letting the tree persecutors get their own way.

That there was such a polarisation is indicative of the big issues coming out about how we view our landscapes. The consultation response was a public recognition of a divide over the England Biodiversity Strategy and its effect on woodland. Tree persecutors, almost invariably associated with the conservation industry, see the strategy and the targets as inviolate (21, 23), but then it was often they that got to choose all the BAP priority species, habitats and targets in the first place. Amongst their responses were those who gave themselves a pivotal role, requiring that they should be engaged early on in public consultation on deforestation sites (24, 25). One respondent even said that no local consultation was necessary when a site was of national priority importance (26). The RSPB, along with almost all the tree persecutors, rejected any obligation for compensatory planting (27).

Pro-tree responses pointed to the lack of legitimacy that the BAP and targets have over private land (28, 29) and I believe in theory have no authoritative hold over public land either. A few thought deforestation was being driven by vested interest, especially that of single issue groups (28, 30-32). Some pushed for greater use of the EIA process (32-35). A strong point made by Paul Nolan of The Mersey Forest was that the proposed programme of open habitat restoration took an early 20th Century view as its baseline. He regarded that as an unhelpful and distorted starting point because it was then that the UK had its lowest ever levels of tree cover (36). Another questioned how targets could be set for restoring open habitat when there could be “no set figure for the amount of heathland that this country should support nor is there any magic figure for the number of nightjars, woodlark, sand lizards etc we should expect to survive in England” (28).

Martin Rejzek was quite clear about the implications of deforestation (38):
"It would, however, be a mistake to regard spaces created by woodland clearing, animal grazing and other human activity as natural habitats even if these areas were open for long periods of time thanks to human intervention. These spaces, when left alone, will tend to naturally regenerate and become woodland again. Trying to restore man-made open spaces is therefore a costly exercise as the management would require continued intervention to keep such space open and in the long term such activity would prove detrimental to both biodiversity and life quality in the UK”

Many had concerns that there was little evidence the supposed biodiversity gains from restoring open habitat by deforestation would be realised (38, 39). Thus it would a loss of woodland for nothing. Moreover, many pointed to the biodiversity value of woodland (40) with Mike Seville, Country Land and Business Association, saying that “It is important that we do not fall into the trap of thinking that only open habitats have biodiversity value” (28)

The policy proposals on deforestation were expected to have been delivered by the FC to Government by now, with a possible launch of the policy in February.

Forest Neighbours and the defence of Gib Torr

Conifer plantation is considered fair game by the conservation industry for deforestation to open habitat. This would have been at the forefront of Staffordshire Wildlife Trust’s (SWT) thinking when the plantation at Gib Torr came up for sale in the mid-90s. The area of 50ha or so of rough grazing (with little evidence of heath) had been planted up in 1972 with a mix of lodge pole pine, Sitka spruce, and Japanese larch, and the rides and glades were managed by the Economic Forestry Group.

SWT bought the plantation largely with support from the Heritage Lottery Fund, and their original proposal for the site was to retain 20% of the conifers and fell the remaining 80% over a 25-year felling cycle (41). The thinking was that the restored open habitat could support moorland birds such as the curlew, a species found on the vast array of moorland that surrounds Gib Torr. As it was, the Trust had already bought 84ha of the adjacent moorland in 1982, and so they combined the plantation within that existing Black Brook Nature Reserve (42). While only a small area of the plantation falls inside the Leek Moors SSSI (a 4.24ha Unit of Fen, marsh and swamp – upland) the rest of the SSSI covers 3,797ha of the surrounding upland area. You will not be surprised that the notification for the SSSI says (43):
“There is little woodland on the moors apart from occasional patches of sallow Salix spp. and birch Betula spp. which provide food and shelter for birds and invertebrates”

The lack of woodland in the area was obviously raised with SWT - discussions had taken place with local people in 2000, some of whom had contacted the FC which said that its preferred option was to clear the conifers over 50 years, with no net loss of trees through replacing them with broadleaves. SWT’s proposals were eventually revised to include replanting, and the application for felling and partial restoration under the Woodland Grant Scheme was approved in 2002. Its aim was the felling of a total of 37ha, with restoration to broadleaves on 10ha of that felled area.

The first two block fellings took place in 2002 and 2003 and brought complaint from newly formed local group Forest Neighbours (FN) at the widespread devastation and smoke pollution. They asked for a moratorium on the felling and recognition that the wood was a valuable nature reserve. This was supported by the outcome of a public meeting held in Flash attended by 100 people who voted overwhelmingly for a cessation of the felling. Another block was felled in 2004 before SWT called a halt and submitted to a consultation process, using external facilitators who were partly paid for by FN.

The consultation process reached agreement in March 2006 that a steering group representing SWT, FN, FC and other bodies, would prepare a 25 year management plan that would balance biodiversity and the existing wildlife, maintain shelter, the micro-climate and the integrity of the landscape. It was also agreed that the felling of the southern tip of the plantation could go ahead, bringing the total area felled to 13.9ha. Only 5ha of that had been replanted with broadleaves. Although the felling licence ran to 2007, the agreement to develop new proposals meant that SWT did not resume the outstanding felling before the licence expired.

That the fellings had an impact could be seen in the visual chaos and degradation of the interior landscape of the plantation. It is known that 37 species of breeding birds had nested in the plantation, including 3 pairs of long-eared owls and five other declining species: bullfinch, goldcrest, redpoll, redstart and song thrush. Another 23 species used the interface with the woods and the surrounding fields. While the deforestation was intended to make way for moorland birds, instead it has driven away woodland birds since about 57 nesting sites were felled including seven of the 37 willow warbler nests, two of the 11 redpoll and two of the three long-eared owl sites, along with those of other local species. In addition, a population of water voles that had been observed over eight years on Black Brook, downstream from the plantation (and identified by the Peak District NPA in 2002) were found to have disappeared in 2004 when flash floods rising over two metres occurred after the fellings in 2003. A hydrology survey subsequently indicated that no more trees should be felled until the replacement tree plantings were established. Doubt revolves around the progress of these trees, which have to achieve an establishment rate of 90% under the conditions of the Woodland Grant Scheme. Pity also the local red deer who were finding their one woodland refuge for many miles disappearing from the landscape.

The Steering Group has never met, but SWT brought forward new proposals in September last year, presented at a meeting in Leek to which I went at the invitation of FN. Although it still set out to fell a further 22ha, the proposals now had an emphasis on restoration of half that with native broadleaf trees as a means of supporting woodland birds, the very same birds that the first fellings had driven away. Unsurprisingly, the driver for this different emphasis arose because of a new funding category in the England Woodland Grant Scheme (EWGS) that is specifically targeted towards restoration of plantations to broadleaves in priority woodland bird areas (44). The area of deforestation to open habitat was proportionately less than earlier proposals, but it just still pointlessly represents a very minor addition to an already vast area of open landscape surrounding this location. Moreover, the wiggly lines on their mapping for the replanted woodland were more to do with their whimsy about edges, rather than being informed by any experience of creating an ecologically functional woodland.

Considerable pressure was exerted by SWT during the presentation for acceptance of the proposals, based on the increasing rate of windthrow of conifers in the plantation, which they maintained would require the shortest cycle of felling of five years only, if the windthrow was not to markedly increase the cost of felling operations. This is the scare story that SWT have been trotting out ever since they bought the plantation 14 years ago, but what cannot be reconciled is that there will be a period of perhaps at least 20-30 years before the replacement plantings will have grown sufficiently to make up for the loss of woodland habitat.

SWT have got it wrong about Gib Torr

The proposals give no indication that SWT has taken into account the BAP priority habitat mapping for Gib Torr (45). This shows the heathland potential that might be restored by deforestation at probably only 10-15% of the total area of the plantation, but inexplicably SWT have already replanted one area of this after the first round of fellings (including planting on the SSSI unit) and the proposals show a second potential area will also be replanted (as well as more of the SSSI unit - how do they get away with it on an open habitat SSSI unit? Double standards here.). Only an area of heathland potential felled at the southern tip is to remain deforested. However, a vast tract of the plantation on the eastern side, that has no heathland potential, is to be deforested. SWT have just got it wrong about Gib Torr. They should have taken note of the priority habitat mapping and then done an Ecological Site Classification analysis across the site to identify the right tree in the right place (46). The logical solution to Gib Torr is that it should have at least 85% woodland cover (outside of the SSSI unit) to ensure a continuing presence of woodland in this very unwooded area, and the strategy would be about the pace and extent of conversion to broadleaves that does not endanger the existing woodland wildlife.

SWT went ahead in December with an application to the FC for a Woodland Improvement Grant that combines approval for felling along with the replanting, as they always intended to and without any concession to the comments on the proposals made by FN. The application lists felling a total of 28.7ha over a five year period, and replacement planting of 16.2ha with native broadleaves (47). Under the same grant scheme, SWT have applied for funding to drive a new forestry road into the plantation, and to create two loading bays off the public roads, portents of the heavy machinery and mass disruption that will be wreaked on Gib Torr.

A formal objection has been submitted by FN during the consultation period on the application, and a petition to the FC has been launched (48). Roz Cullinan, from FN (who set up the petition) said in a recent newspaper report (49):
”Forest Neighbours will oppose this application, because felling has devastated the bird population and put pressure on the existing wildlife. Further felling will completely change the landscape and the area will look like a desert. The Peak Park should be looking after the landscape as the wildlife trust is just playing with the land"

It is the case that applications to the EWGS automatically trigger an opinion from the FC as to whether an Environmental Impact Statement is required before consent can be considered for the proposed deforestation and replanting (50). As is shown here, and by their actions at Swineholes Wood (Swineholes Wood - 'Too many trees being cut down' (51) the evident lack of trust in their competency that SWT always seems to induce within local people demands that this EIA be undertaken, since it would put the onus on SWT to work with FN to come up with plans that do not put the wildlife at Gib Torr under risk.

Mark Fisher, 31 January 2010

(1) The most natural succession of woodland, Self-willed land, November 2009

(2) Biodiversity – the UK Action Plan, Cm 2428, HMSO 1994

(3) Forestry Act 1967 (c. 10)

(4) A New Focus for England’s Woodlands, the England Forestry Strategy, Forestry Commission 1998$FILE/fcefs.pdf

(5) A Strategy for England’s Trees, Woods and Forests, DEFRA 2007

(6) Delivery Plan 2008-2012 - England’s Trees, Woods and Forests, Forestry Commission 2008$FILE/eng-etwf-delivery-plan.pdf

(7) 014/78/09-10, MOOR FARM NATURE RESERVE, Register of new plantings and fellings, Forestry Commission (this entry in the Public Register of grant scheme and felling applications will disappear)

(8) Moor Farm, Lincolnshire Wildlife Trust

(9) Moor Farm SSSI, Natural England

(10) Land Information Search (LIS), Forestry Commission

(11) Frensham Common, Waverley Borough Council

(12) FRENSHAM COMMON + FRENSHAM CHURT – 19900460, Register of Environmental Impact Assessments, Forestry Commission (this entry in the Public Register of Environmental Impact Assessments will disappear)

(13) Cutting down trees to restore open habitats – only now a policy emerges, Self-willed land, March 2009

(14) Environmental Impact Assessment projects and thresholds

(15) Frensham Common Management Plan- Aims and Objectives, 2010 – 2020, Circulation copy, December 2009

(16) Working with the grain of nature –taking it forward: Volume I, Full report on progress under the England Biodiversity Strategy 2002 – 2006, DEFRA 2007

(17) Restoring and expanding open habitats from woods and forests in England:

summary of responses to the consultation, Forestry Commission  July 2009$FILE/090803OpenhabitatssummaryofresponsesFINAL.pdf

(18) Stephanie Wickison, Staffordshire County Council, Open habitats response$FILE/eng-oh-staffs-cc-response-050609.pdf

(19) Dr. Lesley Haskins, Open habitats response$FILE/eng-oh-haskins-response-060609.pdf

(20) Andrew Byfield, Plantlife International, Open habitats response$FILE/eng-oh-plantlife-response-060609.pdf

(21) Simon Harrap, Trustees of Holt Lowes, Open habitats response$FILE/eng-oh-harrap-response-050609.pdf

(22) Nigel Symes, Open habitats response$FILE/eng-oh-symes-response.pdf

(23) Reg Land, Norfolk Wildlife Trust, Open habitats response$FILE/eng-oh-norfolk-wt-response-040609.pdf

(24) Norma Saunders, Sherwood Forest Trust, Open habitats response$FILE/eng-oh-sherwood-forest-trust-response-040609.pdf

(25) Fran Lancaster, Shropshire Biodiversity Partnership, Open habitats response$FILE/eng-oh-shropshire-bio-diversity-pship-response-040609.pdf

(26) Jim White, Footprint Ecology, Open habitats response$FILE/eng-oh-white-response-030609.pdf

(27) Nick Phillips, RSPB, Open habitats response$FILE/eng-oh-rspb-response-050609.pdf

 (28) Mike Seville, Country Land and Business Association, Open habitats response$FILE/eng-oh-clb-assoc-response-050609.pdf

(29) Caroline Harrison, Confederation of Forest Industries (UK) Ltd, Open habitats response$FILE/ConfederationofForestIndustriesopenhabitatresponse.pdf

(30) Nick Hoare, Open habitats response$FILE/eng-oh-hoare-response-170509.pdf

(31) Anon 05.06.09C, Open habitats response$FILE/eng-oh-anonpe-response-050609.pdf

(32) Anon 050609b, Open habitats response$FILE/eng-oh-anonga-response-010609.pdf

(33) Jeremy Walker –Chair, Regional Advisory Committee Yorkshire and The Humber, Open habitats response$FILE/eng-oh-yath-rac-response-010509.pdf

(34) Dr M G Render, Open habitats response$FILE/eng-oh-render-response-050609.pdf

(35) Worcestershire Wildlife Trust and The West Midlands Wildlife Trusts, Open habitats response$FILE/eng-oh-worcs-wmids-wildlife-trusts-response-no-date.pdf

(36) Paul Nolan, The Mersey Forest, Open habitats response$FILE/eng-oh-mersey-forest-response-050609.pdf

(37) Martin Rejzek, Open habitats response$FILE/eng-oh-rejzek-response-280509.pdf

(38) Norfolk Biodiversity Partnership, Open habitats response$FILE/eng-oh-norfolk-biodiversity-response-040609.pdf

(39) East England Regional Advisory Committee, Open habitats response$FILE/eng-oh-ee-rac-response-200509.pdf

(40) Mike and Jemma Box, Forest and Land Management Ltd, Open habitats response$FILE/eng-oh-forest-and-land-mgt-response-050609.pdf

(41) Habitat restoration project at Black Brook Nature Reserve, Frequently Asked Questions? Helen Gee, SWT 23 April 2004,

 (42) Black Brook, Staffordshire Wildlife Trust

(43) Leek Moors SSSI, Natural England

(44) Reversing Woodland Bird Decline, Woodland Improvement Grant, England Woodland Grant Scheme, East Midlands Region, Forestry Commission$FILE/eng-em-woodland-bird-decline-09.pdf

(45) BAP priority habitats, Nature on the Map, Natural England

(46) Ecological Site Classification – supporting decisions from the stand to the landscape scale, FR0102, Forestry Commission$FILE/FR0102esc.pdf

(47) 21334, Black Brook, English Woodland Grant Scheme, Grants and Licences Online, Forestry Commission (this entry in the Public Register of grant scheme and felling applications will disappear)

(48) Stop the Felling and Save Our Trees, Petition to Forestry Commission, Roz Cullinan, 21 January 2010

(49) Families aiming to cut tree-felling scheme at woodland down to size, The Sentinel. 19 January 2010

(50) General Guide to EWGS, Forestry Commission and DEFRA Version 5/March 2009$FILE/ewgs1-guide.pdf

(51) Swineholes Wood - 'Too many trees being cut down', Self-willed land, February 2008